Data Privacy

General privacy policy

Stand 10.01.2023

INTRODUCTION

In accordance with the provisions of Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR), we hereby inform you about the processing of personal data collected about you and your rights under data protection law in this regard. Which data is processed in detail and how it is used depends largely on the requested or agreed services. In order to ensure that you are fully informed about the processing of your personal data in the context of the performance of a contract or the implementation of pre-contractual measures, please take note of the following information.

This privacy policy applies to all companies of the E3 World Group. These are in particular: ET Global GmbH, Excite Europe GmbH, bluepool GmbH, SCF Production GmbH, BIGBLUE Professional Solutions GmbH, SCF Corporate Services GmbH.

DISCLOSURES ON THE RESPONSIBLE

Company	E3 WORLD GmbH
Street and house number	Franklinstraße 61- 63
Postal code	60486
City	Frankfurt am Main
Managing Director	Morten Haure-Petersen
Phone	+49 69 870 0450 0
E-Mail	info@e3.world
Website	www.e3.world

DISCLOURES ON THE DATA PROTECTION OFFICER

Name	Alexander Jaber
E-Mail	ds.e3@cb-sol.de

DEFINITIONS

The data protection declaration is based on the terms used by the European Directive and Ordinance when adopting the General Data Protection Regulation (DS-GVO). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this data protection declaration:

Personal Data

Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).

Processing

Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of Processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

Profiling

Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

Pseudonymization

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

Processor

Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

Recipient

Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, authorities that may receive personal data in the context of a specific investigative task under Union or Member State law are not considered recipients.

Third Party

Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

Consent

Consent is any expression of will in the form of a statement or other unambiguous affirmative action, given voluntarily by the data subject for the specific case in an informed manner and unambiguously, by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

PURPOSES AND LEGAL BASIS OF PROCESSING

We process your personal data in accordance with the provisions of the European Data Protection Regulation (EU-DSGVO) and the German Federal Data Protection Act (BDSG), insofar as this is necessary for the establishment, implementation or performance of a contract or for the implementation of pre-contractual measures. Insofar as the provision of personal data is required for the initiation or implementation of a contractual relationship or in the context of the implementation of pre-contractual measures, processing is lawful pursuant to Art. 6 (1) lit. b DSGVO.

If you give us express consent to process personal data for specific purposes (e.g., disclosure to third parties, evaluation for marketing purposes or promotional approaches), the lawfulness of this processing is based on your consent pursuant to Art. 6 (1) a DSGVO. Consent given can be revoked at any time, with effect for the future.

If necessary and legally permissible, we process your data beyond the actual contractual purposes for the fulfillment of legal obligations pursuant to Art. 6 para. 1 lit. c DSGVO. In addition, processing may be carried out to protect the legitimate interests of us or third parties in accordance with Art. 6 (1) f DSGVO. If necessary, we will inform you separately, stating the legitimate interest, insofar as this is required by law.

In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 para. 1 lit. d DS-GVO.

COLLECTION OF PERSONAL DATA

Types of personal data we may collect:

Salutation, title, first name, last name
Address data
e-mail address
Telephone number (landline and/or mobile)
Fax number (if available & requested), if applicable
bank account data, if applicable
date of birth, if applicable
Application data, if applicable

In addition, further information may be collected that is necessary for the fulfillment of the contract/order/etc. with you.

STORAGE OF PERSONAL DATA

We store your data only as long as this is either required by law or necessary to fulfill a contractual obligation or use agreed with you. If the purpose of use ceases to apply and there is also no other legal obligation to retain your data, your data will be deleted.

USE OF PERSONAL DATA

We use your data for the following purposes:

to identify you as a customer
to provide contractual services, service and customer care
to send invoices and process payments or, if necessary, as part of the dunning process;
to process an application procedure
Within the legally prescribed framework for:
for the assertion of claims
providing information and, if necessary, forwarding to government agencies

As a rule, the processing of personal data takes place on the occasion of your inquiry with us and is necessary for the aforementioned purposes for the processing of your order and for the fulfillment of obligations arising from the underlying contract.

The collected personal data will be stored at most until the expiry of the statutory retention obligation (according to HGB; StGB or AO. The corresponding retention periods here are regularly 6 or 10 years) and then deleted. This does not apply exceptionally if you have consented to storage beyond this. If we use service providers for processing, the full responsibility for data processing remains with our company.

YOUR RIGHTS AS A DATA SUBJECT

1. RIGHT TO CONFIRMATION AND INFORMATION ART. 15 DS-GVO

You have the right to request confirmation from us as to whether personal data concerning you is being processed.

You have the right to receive from us, at any time and free of charge, information about the personal data stored about you, as well as a copy of this data in accordance with the legal provisions.

2. RIGHT TO CONFIRMATION AND INFORMATION ART. 15 DS-GVO

You have the right to request that inaccurate personal data concerning you be corrected. You also have the right to request that incomplete personal data be completed, taking into account the purposes of the processing.

3. DELETION ART. 17 DS-GVO

You have the right to demand that we delete the personal data concerning you without delay, provided that one of the reasons provided for by law applies and to the extent that the processing or storage is not necessary.

4. RESTRICTION OF RPOCESSING ART. 18 DS-GVO

You have the right to demand that we restrict processing if one of the legal requirements applies.

5. DATA PORTABILITY ART. 20 DS-GVO

You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO or on a contract pursuant to Art. 6(1)(b) DS-GVO and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have the personal data transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.

6. OBJECTION ART. 21 DS-GVO

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DS-GVO.

This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

In individual cases, we process personal data to conduct direct marketing. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is related to such direct advertising. If you object to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the DS-GVO, unless such processing is necessary for the performance of a task carried out in the public interest.

You are free to exercise your right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

7. REVOCATION OF A DATA PROTECTION CONSENT

You have the right to revoke consent to the processing of personal data at any time with effect for the future.

You can contact us in confidence with your request.

If you wish to object to the processing, please send us a message to the above address with the following content:

To: ds.e3@cb-sol.de | E3 World GmbH, Franklinstraße 61- 63, 60486 Frankfurt am Main, Germany

I hereby revoke [first name, last name, street, house number, postal code, city] my consent to the processing of my personal data.

8. COMPLIANT TO A SUPERVISORY AUTHORITY

You have the right to lodge a complaint about our processing of personal data with a supervisory authority responsible for data protection.

You also have the right to complain about our processing of your personal data to the data protection supervisory authority in your federal state (pursuant to Article 77 of the GDPR).

In the event of a complaint, please contact us directly or the competent supervisory authority in your federal state:

The contact details for these can be found at the following link:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

The supervisory authority responsible for our company is:

The Hessian Commissioner for Data Protection and Freedom of Information.

Prof. Dr. Alexander Roßnagel

P.O. Box 31 63

65021 Wiesbaden

Gustav-Stresemann-Ring 1

65189 Wiesbaden

Phone: 06 11/140 80

E-mail: poststelle@datenschutz.hessen.de

https://www.bfdi.bund.de/SharedDocs/Adressen/DE/LfD/Hessen.html?nn=304054

DATA SHARE

We pass on your personal data within our group of companies exclusively to those areas and persons who need this data to fulfill contractual and legal obligations or to implement our legitimate interest as well as the fulfillment of orders with your company.

Otherwise, data will only be passed on to recipients outside the company if this is permitted or required by law, if the transfer is necessary for the execution and thus the fulfillment of the contract or, at your request, for the implementation of pre-contractual measures, if we have your consent or if we are authorized to provide information. Under these conditions, recipients of personal data may be, for example:

Public bodies and institutions (e.g. public prosecutor's office, police, supervisory authorities, tax office) if there is a legal or official obligation.
Recipients to whom disclosure is directly necessary for the purpose of establishing or fulfilling a contract (all companies belonging to the E3 World group of companies).

In order to protect your data and to allow us to transfer data to third countries (outside the EU/EEA) if necessary, we have entered into commissioned processing agreements based on the standard contractual clauses of the European Commission.

1. HUBSPOT

We use the services of the provider Hubspot. HubSpot is a software company from the USA (HubSpot, Inc., 25 First Street, 2nd Floor Cambridge, MA 02141, USA) with a branch office in Ireland 8imited at 2nd Floor 30 North Wall Quay, Dublin 1, Ireland).

The processing of your data takes place for the purpose of marketing, lead generation and customer service purposes.

The following data is collected and processed:

Details of your company and your contact information (address, first and last name, telephone number, e-mail).

The transfer of data to Hubspot is based on the standard contractual clauses of the EU Commission. In order to ensure an adequate level of data protection for data transfers to third countries, further measures in terms of encryption of data at rest and data in transit are implemented. Please refer to the terms of use and privacy statements of Hubspot in this regard.

https://legal.hubspot.com/de/privacy-policy

The legal basis of the processing is lawful pursuant to Art. 6 (1) lit. b DSGVO, insofar as the provision of personal data is necessary for the initiation or implementation of a contractual relationship or in the context of the implementation of pre-contractual measures.

Furthermore, the processing of personal data for the formation of personal relationships takes place on the basis of Art. 6 para. 1 lit. f.

The legal basis for the processing of marketing permission (newsletter, advertising) is your consent pursuant to Art. 6 (1) lit. a DSGVO.

The personal data will only be processed for the period in which this is necessary for the fulfillment of the purpose or for the fulfillment of legal requirements. After the end of the purpose and if legal requirements no longer apply, the data will be deleted after an appropriate retention period.

2. MAKE.COM

We use the integration service Make.com (formerly Integromat) of the software provider Celonis Inc. This is a company from the USA with its headquarters at One World Trade Center, 87th Floor, 10007 New York, United States of America.

The processing of your data takes place for the purpose of customer acquisition, customer care and customer retention. We use make.com to integrate various databases and web tools. Make.com is a web service that links automated actions between different web tools and synchronizes their applications with each other so that they execute the desired processes. In this regard, Make.com automates our processing operations and ensures different workflows to efficiently design work processes in our processing system.

The following data is collected and processed:

Information about your company (company, street, zip code, city, country, phone number, email, industry and website).

The transfer of data to Celonis is based on the standard contractual clauses of the EU Commission. In order to ensure an adequate level of data protection for data transfers to third countries, further measures in terms of encryption are implemented. Please refer to the terms of use and privacy policy of Celonis in this regard:

https://www.make.com/en/terms-and-conditions

https://www.make.com/en/privacy-notice

The described data processing takes place for the formation of personal relationships on the basis of Art. 6 para. 1 lit. f DSGVO or is carried out on the basis of our legitimate interests in the efficient design of our work processes.

The personal data is only processed for the duration in which this is necessary for the fulfillment of the purpose or for the fulfillment of legal requirements. After the end of the purpose and if legal requirements no longer apply, the data will be deleted after an appropriate retention period.

3. PIPELINER

We use the services of the CRM software provider Pipeliner. Pipeliner is a software company from the USA with a branch office and sales in Slovakia and Austria (P. O. Box 492 Pacific Palisades, CA 90272, United States of America, Rontgenova 26 85101 Bratislava, Slovakia European Union, Pipeliner CRM GMBH at Kärntnerstraße 7/6, A-1010 Vienna, Austria).

The processing of your data takes place for the purpose of customer acquisition, customer care and customer retention.

The following data is collected and processed:

Details of your company and your contact information (address, first and last name, telephone number, e-mail, possibly date of birth (with consent), department, industry, industry experience, title, role title, social media account, feedback on the assessment of our performance and quality), marketing permission, details about you in the context of customer retention (usually only with explicit consent or due to legitimate interest: individual address and contact details, personality traits, photos), consent to receive newsletters or advertising.

The transfer of data to Pipeliner is based on the standard contractual clauses of the EU Commission. In order to ensure an adequate level of data protection for data transfers to third countries, further measures in terms of encryption of data at rest and data in transit are implemented. Please refer to Pipeliner's terms of use and privacy policy in this regard.

https://www.pipelinersales.com/terms/

https://www.pipelinersales.com/privacy/

Furthermore, the processing of personal data for the formation of personal relationships takes place on the basis of Art. 6 para. 1 lit. f.

The legal basis for the processing of marketing permission (newsletter, advertising) is your consent pursuant to Art. 6 (1) lit. a DSGVO.

4. Zoho

We use the services of the CRM provider Zoho Corporation ("Zoho"). Zoho is a company with a branch in Germany (Zoho Corporation GMBH, Trinkausstr. 7, 40213 Düsseldorf).

The processing of your data takes place for the purpose of organizing existing and potential customers, as well as managing customer contacts and sales and communication processes.

The use of the CRM system also enables us to analyze and optimize our customer-related processes. Customer data is stored on Zoho CRM servers in the Netherlands.

The following data is collected and processed:

Contact information (address, contact person last name, phone number, email) and, if applicable, consent to receive newsletters or advertising.

The transfer of data to Zoho is based on the standard contractual clauses of the EU Commission. To ensure an adequate level of data protection for data transfers to third countries. For support services, data may be transferred to Zoho Corporation Pvt. Ltd (Ltd.Estancia IT Park,Plot no. 140, 151, GST Road, Vallancheri Chengalpattu District - 603202, INDIA).

Please refer to Zoho's Terms of Use and Privacy Policy in this regard.

https://www.zoho.com/de/privacy.html

The processing of personal data takes place for the purpose of forming personal relationships on the basis of Art. 6 (1) lit. f.

The legal basis for the processing of marketing permission (newsletter, advertising) is your consent pursuant to Art. 6 para. 1 lit. a DSGVO.

GENERAL TOPICS

1. APPLICATION

We store your personal data for as long as is necessary for the decision on your application. Your personal data or application documents will be deleted a maximum of six months after the end of the application process (e.g. notification of the rejection decision), unless longer storage is required or permitted by law. We store your personal data beyond this only insofar as this is required by law or in the specific case for the assertion, exercise or defense of legal claims for the duration of a legal dispute.

In the event that you have consented to a longer storage of your personal data, we will store it in accordance with your declaration of consent.

If an employment relationship, apprenticeship or trainee relationship is established following the application process, your data will initially continue to be stored, insofar as this is necessary and permissible, and then transferred to the personnel file.

2. CONCLUSION OF CONTRACTS AND ORDER PROCESSING

Personal data that you provide to us in the course of concluding a contract shall be used exclusively for the purpose and processing of the contract and shall be deleted after the purpose no longer applies or at the latest after expiry of the statutory retention period.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Article 6 (1) lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.

In addition, we are subject to various storage and documentation obligations, which result, among other things, from the German Commercial Code (HGB) and the German Fiscal Code (AO). The periods prescribed there for storage or documentation are two to ten years.

Finally, the storage period is also based on the statutory limitation periods, which, for example, according to §§ 195 et seq. of the German Civil Code (BGB), are generally three years, but in certain cases can be up to thirty years.

3. DISTRIBUTION

For the purpose of selling and distributing goods, we collect the personal data of interested parties and customers. The data regularly collected in this context includes:

- Name

- title

- Name of the company

- Address of the company

- Billing address

- E-mail address

- Telephone number

- Customer number, if applicable

- Customer type, if applicable

- Contact information

- Contact history

- Appointment data

- Bank details

- If applicable, sales tax identification number

- Contract data

If you give us your express consent to process personal data for specific purposes (e.g., transfer to third parties, evaluation for marketing purposes or advertising), the lawfulness of this processing is given on the basis of your consent in accordance with Art. 6 Para. 1 lit. a DSGVO. Consent given can be revoked at any time, with effect for the future. In addition, processing may be carried out to protect the legitimate interests of us or third parties in accordance with Art. 6 (1) (f) DSGVO or Recital 47 (2) e.g. To maintain the customer relationship and the relationship with the contact person.

We do not share your personal data with third parties unless this is necessary in the context of providing the services. If we use service providers for processing, the full responsibility for data processing remains with our company. The data will be deleted after the business relationship has been concluded or after the purpose for which it was collected has ceased to apply, unless there are any legal retention periods beyond this. In the case of personal sales/distribution data that is relevant to accounting, storage periods of 10 years generally apply (§ 147 Abs 3 und 4, AO).

4. TRADE FAIRS, EVENTS & FUNCTIONS

In the case of data collected from interested parties, customers (and, where applicable, participants in competitions) in the course of trade fairs, events and functions, the data is used exclusively for the purpose for which it was collected. We store your data only as long as this is either required by law or necessary to fulfill a contractual obligation or use agreed with you. If the purpose of use ceases to apply and there is also no other legal obligation to retain your data, your data will be deleted.

5. MARKET RESEARCH

For the purpose of market research, customer centricity and customer satisfaction, we conduct interviews and process the following personal data of suppliers, customers and business partners for this purpose:

- Name of the company

- address data

- Data of the contractual relationship

- Relationship history

- Transaction data

- Order history

- Inquiries

The processing of personal data takes place for market research on the basis of Art. 6 para. 1 lit. f with the following interests:

- The further development of products and services as well as other measures for the management of business transactions and processes.

- Correspondence in connection with the initiation, implementation or evaluation of studies

- Evaluation of studies and preparation of the results on the studies

The personal data will only be processed for the time necessary to fulfill the purpose or to comply with legal requirements. After the end of the purpose and when legal requirements no longer apply, the data is deleted again.

DATA ENRICHMENT OF COMPANY MASTER DATA

In the context of addressing our customers in advertising, we have the relevant company data supplemented by Dun & Bradstreet Deutschland GmbH, Darmstadt. Further information on data processing at Dun & Bradstreet can be found at www.dnb.com/de.

CHANGES / UPDATES TO OUR PRIVACY POLICY

We occasionally adapt this data protection declaration in order to keep it up to date with the operational circumstances, our data processing and legal requirements. The current data protection declaration will then apply to your next visit to our website. At this point, we will also inform you if changes require your cooperation (e.g. consent) or other individual user information.

This privacy policy is currently valid and has the status: January 2023.