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Toshiba

Privacy Policy

EXTERNAL PRIVACY NOTICE
Last Updated 29th June 2023

We respect the privacy of every person who visits or registers with Toshiba Electronics Europe GmbH’s website (the “Site”) and we are further committed to ensuring a safe online experience. We also respect the privacy of our suppliers and service providers and of every person who uses the products and services that we make available from the Site or who engages with us to use the products or services that Toshiba Electronics Europe GmbH (“TEE”) provides (be it through the Site or not) (our “Services”) or whose personal information we may process as a result of providing the Services to others or who applies to work at TEE.

To Russian citizens:
We respect the privacy and security of your personal data wherever we provide our services and products via the Site. Therefore, through technical and organizational measures, we have ensured that personal data of Russian citizens will not be stored, used and forwarded outside of the Russian territory. As a consequence, we are regrettably not able to offer all of the Site services (such as newsletters, for example) to Russian citizens.

 

  1. PURPOSE OF THIS POLICY
  2. WHO ARE WE AND WHAT DO WE DO?
  3. HOW TO CONTACT US?
  4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
  5. HOW DO WE OBTAIN YOUR CONSENT?
  6. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES
  7. THIRD PARTY CONTRACTORS AND OTHER CONTROLLERS
  8. EXTRA-EEA TRANSFERS
  9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
  10. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
  11. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
  12. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS
  13. CHANGES TO THIS PRIVACY NOTICE

1 PURPOSE OF THIS POLICY

This privacy notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information. For more information click here.

This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to others or when you apply to work at TEE. Please take a moment to read and understand it.

Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

2 WHO ARE WE AND WHAT DO WE DO?

The Site and our Services are operated by TEE, (“we”, “us” or “our”). For more information click here.

Toshiba Electronics Europe GmbH is the data controller responsible for your personal information processed via the Site.

Toshiba Electronics Europe GmbH is a German company with registered company number HRB22487 and whose registered office is at Hansaallee 181, 40549 Düsseldorf, Germany.

3 HOW TO CONTACT US?

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact our Data Protection Officer at:

Toshiba Electronics Europe GmbH

Data Protection Officer

Mr. Johannes Schwiegk

c/o Datenzeit GmbH

Friedrich-Engels-Allee 200,

42285 Wuppertal

Email: [email protected]

4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) help us deliver our Services; (iii) improve, develop and market new Services; (iv) carry out requests made by you on the Site or in relation to our Services; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other customers or subscribers and users of the Site or our Services; (ix) provide support for the provision of our Services; (x) recruitment purposes; (xi) to receive services and products from our customers, contractors, suppliers and service providers and (xii) use as otherwise required or permitted by law.

To undertake these goals we may process the following personal information:

If you are a visitor to the Site:

  • Name and job title.
  • Contact information including email address.
  • Demographic information such as postcode, preferences and interests.
  • Other information relevant to provision of Services.

If you are a customer or subscriber in receipt of our Services or prospective customer or subscriber :

  • Name and job title.
  • Contact information including email address.
  • Payment information.
  • Other information relevant to provision of Services.
  • Information that you provide to us as part of our providing the Services to you which depends on the nature of your agreement with TEE.
  • Relevant information as required by regulatory Know Your Client and or Anti Money Laundering regulations. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from the prospective client or through the use of online sources or both.

Primarily TEE is engaged by corporate customers (i.e. other corporate entities) and as such those customers are not data subjects. However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ workers or subscribers.) 

If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided in question.

The following is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of our business.

For instance, if we are providing technical support to a corporate customer for the benefit of a subscriber we may be provided with, and then process, personal information about that subscriber including but not limited to the subscriber’s name and contact details.

We might also need to process personal information in relation to corporate customers’ workers who use a Toshiba product in the course of their work for our corporate customer. 

If you are a customer, contractor, supplier or other service provider providing services or selling products to TEE:

  • Name and job title.
  • Contact information including email address.
  • Payment information.
  • Other information relevant to your provision of the services or goods to TEE.
  • Information that you provide to us as part of you providing the services or goods to us which depends on the nature of your agreement with TEE.

If you are a potential recruit to a TEE office:

  • Name and job title.
  • Contact information including email address.
  • Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
  • Other information relevant to potential recruitment to TEE.

In particular, we may use your personal information for the following purposes:

  • Fulfilment of Services. For more information click here.

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services.

Who do we share your personal information with for this purpose?

We may share personal information with a variety of the following categories of third parties as necessary when providing the Services:

  • Other Toshiba group companies within or outside the EU
  • Other external service providers which may be based within or outside the EU
  • Other customers, suppliers, contractors and users of our Services

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.

  • Receiving goods or services from TEE’s customers, contractors, suppliers and service providers. For more information click here.

We collect and maintain personal information that you voluntarily submit to us when providing services or goods to us.

Who do we share your personal information with for this purpose?

We may share personal information with a variety of the following categories of third parties as necessary when providing the Services:  

  • Other Toshiba group companies within or outside the EU
  • Other external service providers which may be based within or outside the EU

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest.

  • Your feedback about our Services. For more information click here.

From time to we will contact you to invite you to provide feedback about our Services in the form of online or postal. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our Services.

Who do we share your personal information with for these purposes?

We may use a third party service provider to assist us with client surveys and feedback requests. We may also share your personal data with other Toshiba group companies within and outside the EU.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

  • Customer services. For more information click here.

Our Site uses various user interfaces to allow you to request information about our Services: these include electronic enquiry forms. Contact information may be requested in each case, together with details of other personal information that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

We may share personal information with a variety of the following categories of third parties as necessary when providing the Services:

  • Other Toshiba group companies within or outside the EU
  • Other external service providers which may be based within or outside the EU
  • Other customers and users of our Services

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

What is our legal basis?

It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

  • Business administration and legal compliance. For more information click here.

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations (including Know Your Client, Anti-Money Laundering or Anti-Bribery or similar obligations including but without limitation maintaining regulatory insurance);
  • to enforce our legal rights;
  • protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities. We may also share your personal information with other Toshiba group companies within or outside the EU.

What is our legal basis?

Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

We use your personal information for the following recruitment purposes:

To assess your suitability for any position for which you may apply at TEE whether such application has been received by us online, via email or by hard copy or in person application.

Who do we share your personal information with for these purposes?

We will not share your personal information as part of the recruitment process.

What is our legal basis?

Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for TEE. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

  • Client insight and analysis. For more information click here.

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences. 

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

We may also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers to assist us with client insight analytics. These providers include for example Google Analytics. Please see Section 6 of this Privacy Policy below.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see Section 6 of this Privacy Policy below.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients. Please also see Section 6 of this Privacy Policy below.

  • Marketing communications.

We may carry out the following marketing activities using your personal information:

  • Postal marketing. For more information click here.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, such as your postal address, it is usually in our legitimate interest to use your personal information for postal marketing. If and to the extent your consent is lawfully required, we will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.

  • Email marketing. For more information click here.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

  • Online personalised advertising. For more information click here.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised online advertising.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers who assist us with our online personalised advertising campaigns.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only use your personal information where we have a lawful right to do so.

  • Social media remarketing. For more information click here.

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised advertising on social media channels operated by Facebook, LinkedIn, Youtube and/or Google where you are a registered user of such services. 

We may do this by using e.g. Facebook Client Audiences and/or Google Client Match respectively.

Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns. 

Your encrypted email address may also be shared by us or our third party service providers with YouTube, LinkedIn, Facebook and/or Google under the terms of their services respectively.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us using your email address and/or sharing your email address in an encrypted format with LinkedIn, YouTube, Facebook and/or Google respectively for marketing purposes.

  • Social media insight. For more information click here.

Where you are a registered user of LinkedIn, YouTube, Facebook, or of a Google service, we may use your email address in an encrypted format to enable LinkedIn, YouTube, Facebook and Google to find other registered users of their services that share similar interests to you based on: 

  • information that we observe about you from your interactions with our Site, our email communications to you and/or Services (see the Client Insight and Analysis section above for more details of the information collected and how it is collected); and 
  • the information LinkedIn, YouTube, Facebook and/or Google hold about you. 

We may do this by using e.g. Facebook ad manager, YouTube True View Advertising, LinkedIn Matched Audiences, Facebook Lookalike Audiences and/or Google Similar Audience respectively.

Please note that such activity is subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns. 

Your encrypted email address may also be shared by us or our third party marketing consultancies with LinkedIn, YouTube, Facebook and/or Google under the terms of their services respectively.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only use your personal information where we have a lawful right to do so.

  • Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5 HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail or post using the contact details set out in this Privacy Notice.

6 OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

In order to improve the Site and the Services provided thereon and to provide more convenient, relevant experiences to our customers, we and our agents may use “cookies”, “web beacons” and similar devices to track your activities, e.g. the analytics service Adobe Analytics provided by Adobe Systems Software Ireland Ltd. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. A cookie functions as your identification card and enables TEE to record your passwords and preferences. A cookie cannot be executed as code or deliver viruses. A web beacon is a small transparent .gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. A similar tool may be used that may send data to a server when a set of user-initiated events occur such as for instance when the “Add to Cart” button is clicked. This tool is similar to a cookie. It tracks your visit and the data can only be read by the server that receives the data. It is different than a cookie in that it is not browser-based, may not function as an identification card and does not store any data on your computer.

While TEE uses cookies and similar tools to track your use of the Site and the Services provided thereon and web servers automatically log the IP/Internet address of your computer, TEE does not generally use this information to identify you personally. Exceptions to this are noted in this Privacy Policy. If you expressly provide consent for the Site and/or Services provided thereon to “remember” the unique identifier that you select when you register for various activities on the Site or Service, that unique identifier will be stored as a persistent cookie on your computer and that unique identifier will be linked to your registration information. As a result, your navigation path around the Site and the Services provided thereon will be tracked in identifiable form. Most browsers are initially set to accept cookies, and most services that include similar devices are typically initially activated to collect data. You can set your browser to notify you when you receive a cookie. This gives you the chance to decide whether or not to accept it (Cookies are obligatory for some web pages that require authorization. Users choosing not to accept cookies or similar tools will probably not be able to access those pages or the related products and/or services). Information about non-cookie tracking devices and their features, including disabling options, are contained in the information materials provided with such services or on Site pages relating to such services.

In addition to the tools and cookies listed below, the following cookie related to the searching functionality provided on the Site is set:

  • PHPSESSID

Google AdWords Remarketing

We use Google AdWords Remarketing to advertise TEE across the internet, in particular Google Display Network. AdWords remarketing will display ads to you based on what parts of the TEE Site you visited. To achieve this, the Site places a cookie in your web browser. This cookie does not in any way identify you or give access to your computer or mobile device.

The cookie is only used to indicate the following to other websites: “This person visited a particular page, so show them ads relating to that page.”

Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.

If you do not wish to see ads from TEE, you can opt out in the following ways:

Disable “Ads Personalization” in Google’s Ads Settings.

Opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative’s opt-out page.

Google Analytics 

This Site uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics can use cookies on the user’s computer (for cookies, see above) and allows us to analyze your use of our website. For example, we take into account which content you have called up within one or various usage processes, which search terms you have used and how you have interacted with our online offering overall. The time of use and duration are also stored, as well as technical aspects of your end devices and browsers used. For this purpose, pseudonymous user profiles are created with information from the use of various devices. Through the use of Google Analytics, data on the geographical location is determined and provided. For this purpose, the following metadata is collected based on the IP search: City (and the derived latitude and longitude of the city), Continent, Country, Region, Subcontinent (and the ID-based equivalents). To ensure the protection of personal data of European users in the EU, Google receives and processes all data via domains and servers within the EU. The IP address of the users is not logged and is shortened by the last two digits by default, whereby the shortening with regard to European users takes place on European servers.

The information obtained through the use of Google Analytics is used by Google on our behalf to evaluate your use of our website, to compile reports on website activity for us and to provide other services relating to the use of our website and the internet. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Full or unabbreviated IP addresses are not transferred to Google servers in the USA, so that it should be excluded that personal data is transferred to the USA. The USA is considered by the European Court of Justice to be a country with an insufficient level of data protection according to European standards. In particular, there is a risk that your data may be processed by US authorities for control and monitoring purposes. Furthermore, risks may arise for you because it may be more difficult to enforce your rights in the USA. For cases in which personal data is transferred to the USA, Google invokes the standard contractual clauses of the European Union after the discontinuation of the EU-US Privacy Shield, cf. https://business.safety.google/adsprocessorterms/, as well as additional measures that can be accessed at the following link: https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf

The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. a DSGVO, i.e. your consent, which you have given via our cookie banner or consent management tool for the described data processing.

The processing of users’ personal data enables us to analyze the surfing behavior of our users. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. By anonymizing the IP addresses, the interest of the users in their protection of personal data is sufficiently taken into account.

The data is deleted as soon as it is no longer required for our recording purposes. Furthermore, we would like to point out that we, as the provider of the pages, have no further knowledge of the content of the transmitted data or its use by Google. You can find more information on this in Google’s privacy policy at https://policies.google.com/privacy.

You can revoke your consent at any time with effect for the future by changing the settings in our cookie banner or consent management tool.

In addition, you can prevent cookies from being stored on your computer by setting your browser software accordingly. In this case, you may not be able to use all the functions of our website to their full extent. To prevent the collection of data generated by the cookies and related to your use of our website (including your IP address) by Google as well as the processing of this data by Google, a browser plug-in is available for download and subsequent installation at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can also object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the network advertising initiative (https://optout.networkadvertising.org/) and additionally the US website (https://www.aboutads.info/choices) or the European website (https://www.youronlinechoices.com/uk/your-ad-choices/).

7 THIRD PARTY CONTRACTORS AND OTHER CONTROLLERS

As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, service providers to assist TEE with for example warranty inquiries and who will process personal information on our behalf and at our direction.  We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

Further, we may appoint external data controllers in common where necessary to deliver the Services (for example, but without limitation other Toshiba entities). When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation where necessary putting appropriate safeguards in place to ensure any personal information is processed according to our legal and regulatory obligations.

8 EXTRA-EEA TRANSFERS

If you are based within the EEA, please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA (including to Toshiba’s Japanese entities) and other Toshiba entities via the applicable Data Sharing Agreements which utilise model contracts as the extra-EEA transfer mechanism). When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. You can request a copy of the model clauses which we entered into by contacting us.

9 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will retain relevant personal information for as long as it is necessary in order to fulfil the relevant purposes described in this Privacy Notice and to comply with other legal obligations (for example in the areas of finance and accounting). We may then destroy such files without further notice or liability.

10 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration. For more information click here.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our members, employees, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.

11 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

  • Your right of access. For more information click here.

If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

  • Your right to rectification. For more information click here.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to erasure. For more information click here.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible (the right to be forgotten). If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to restrict processing. For more information click here.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

  • Your right to data portability. For more information click here.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

  • Your right to object. For more information click here.

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing. Please refer to section four above which outlines our marketing activities.
  • Your rights in relation to automated decision-making and profiling. For more information click here.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

  • Your right to withdraw consent. For more information click here.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

  • Your right to lodge a complaint with the supervisory authority. For more information click here.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the North Rhine-Westphalia Commissioner for Data Protection and Freedom of Information (LDI NRW). You can find details about how to do this on the LDI NRW website at https://www.ldi.nrw.de/index.php.

12 COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as TEE has no control over information that is submitted to, or collected by, these third parties.

13 CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy Notice from time to time. For more information click here.

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.