DATA PROTECTION

SVEMA HYGIENE GMBH : CUSTOMER DATA PRIVACY POLICY

Overview

SVEMA is committed to maintaining the accuracy and security of your personal information. This Customer Privacy Policy (“Privacy Policy”) explains what types of personal information we may collect about our Customers, why it is collected, how we use your personal information and when we might transfer your personal information to a third party.

In this Privacy Policy the term:

a. “Customer” means all actual and potential customers of SVEMA. Customers are also referred to in this Privacy Policy as “you” or “your”.

b. “SVEMA” means Svema Hygiene GmbH and all of subsidiaries and affiliates. SVEMA is also referred to as “we”, “us” and “our”.

1. Contact Information.

The Data Controllers are:

Svema Hygiene GmbH
Paul-Ehrlich-Strasse 18
63322 Rödermark
Germany
M.Morgenstern@svemagroup.com

This Customer Data Privacy Policy describes a broad range of data processing activities. It is built upon current law and information fair handling principles. We will adjust this Privacy Policy to comply with the law of the country in which you reside if that law is more restrictive.

2. Applicability of Other SVEMA Policies

This Privacy Policy applies only to the personal information of Customers that we collect in ways other than through your use of a SVEMA website, and then process, use and transfer. Other policies, such as our Online Privacy Policy, apply to our use of your personal information.

3. What is Personal Information?

Personal information (“PI”) means any information that (i) directly and clearly identifies an individual, for example, your name, or (ii) can be used in combination with other information to identify an individual, for example, your home address.

4. What is Sensitive Personal Information?

Sensitive personal information (“Sensitive Information”) is a subset of PI that is more sensitive in nature than PI. It reveals race, religion, national origin, political opinions, union membership, sexual preferences, sexual orientation, genetic data and biometric data.

5. What PI Do We Collect?

We collect and maintain different types of PI about you in accordance with applicable law. Some examples include:

• Business name and address; business and mobile phone numbers; name of main purchasing contact and his or her phone number and email address; name of other customer employees and their phone numbers and email addresses; name and email address of end users.
• Voicemails, e-mails, correspondence, documents and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment.

If you fail to provide certain information when requested, we may not be able to perform all our legal and contractual obligations or carry out all activities such as providing you with marketing materials. We will make it clear if and when this situation arises and what the consequences of not providing your PI will be.

6. Who Gives Your PI to Us?

We collect your PI from you.

7. On What Legal Basis Does SVEMA Collect and Process Your PI?

There are a number of reasons why SVEMA collects and processes your PI. Those reasons include:

• You have given us consent. The consent can be in writing, verbally or implied.
• Processing is needed to perform a contract between you and SVEMA. For example, we may ask for bank account information so SVEMA can process payments if necessary.
• Processing is needed for SVEMA to comply with a legal obligation. For example, SVEMA needs certain PI to enable us to process your purchase order.

8. How Do We Use the PI We Collect from You?

SVEMA uses your PI:

• To manage all aspects of the customer/potential customer relationship. To provide corporate incentive programmes.
• Notification of requests from exhibitions, sample requests, general enquiries concerning our products and services.

9. Does SVEMA Share Your PI with Third Parties?

• Yes. SVEMA sometimes shares your PI with parties outside SVEMA. Examples include:
• If you request us do to so, or provide your consent to us
• In order to provide services and benefits related to the customer/potential customer relationship. Those include third parties which operate customer and prospect relationship management systems
• If SVEMA sells a business, your PI may be sent to the buyer of the business. If SVEMA buys a business, it may acquire the PI of customers of that business
• When required by law or by order of a court or other government agency
• If SVEMA determines it is necessary or desirable to comply with the law or to protect or defend our, safety, rights or property or those of a third party
• Where the PI is public information
• To seek advice from our professional advisers
• To provide incentive programmes for our distributors, customers and end-users.

When we share your PI with a third party, that third party is providing a service to SVEMA to help us manage our relationship with you. We require that they only use or disclose your PI for the purpose for which it is provided, and that they use reasonable safeguards to maintain its accuracy, completeness and integrity and to preclude illegal access. This does not apply when we receive an order or request from a court or other government agency to provide them with your PI or in an emergency.

10. Your Rights Regarding Your PI.

You have the right to be informed about why SVEMA collects your PI and how SVEMA uses your PI. This Privacy Policy provides you with that information.

SVEMA will provide you with access to your PI. To access your PI: 

Customers located in any european country should contact Maximilian Morgenstern at M.Morgenstern@svemagroup.com.

When requesting access to your PI, we may request specific information from you to enable us to confirm your identity. There will be no charge to request and receive your PI. If SVEMA cannot provide you with access to your PI, we will inform you of the reasons why as long as we are permitted by law to do so.
You have the following rights:
A. Rectification (also known as Correction).
SVEMA attempts to be sure that your PI in our possession is accurate, current and complete. If you believe that the PI SVEMA collects about you is incorrect, incomplete or outdated, you may request the revision or correction of that PI.

B. Erasure (the ‘right to be forgotten’).
You may request that we delete the PI which SVEMA retains about you. SVEMA may retain your PI for as long as we believe it is necessary to fulfill the purposes for which the PI was collected.

There are instances where applicable law allows or requires us to refuse to delete your PI. In the event that we cannot delete your PI, we will inform you of the reasons why.

C. Restrict Processing.
You may request that SVEMA restricts processing your PI under certain circumstances, including you believe the PI is not accurate. 

D. Portability.
You have the right to receive from SVEMA your PI in machine readable format where the processing is done by automated means.

E. Objection.
You have the right in limited circumstances to object to SVEMA processing your PI.

F. Automated Processing.
You have the right to ask us to stop using your PI for automated processing such as profiling.

G. Withdraw Consent.
Where SVEMA collects and processes your PI based on your consent, you have the right to withdraw consent.

H. Define post-mortem guidelines:
Where permitted by law, You may define guidelines as to the storage, erasure and communication of your PI after your death. These guidelines may be general or specific.
You also have a right to lodge a complaint with a supervisory authority, in particular in the member state in the European Union where you are habitually resident, where you work or where an alleged infringement of data protection law has taken place.

11. Retention of your PI

We will only retain your PI for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

In general terms, this means that we will retain your PI for the duration of your engagement with us and for the length of any applicable limitation period for claims which might be brought against us later. There are also certain types of information, such as tax records, which require to be retained for a certain period by law.

In some circumstances we may anonymise your PI so that it can no longer be associated with you, in which case we may use such information without further notice to you.

PI provided by prospective customers who do not become an actual customer will be kept for ten (10) years after the last contact with the prospect.

12. Does SVEMA collect or retain PI about children?

No. SVEMA does not acquire or retain PI about customers children.

13. Security of Collected Information

We are committed to protecting the security of the PI we collect from you. SVEMA uses reasonable physical, technical and administrative safeguards to help protect the information from destruction, loss and unauthorised or inappropriate access or use.

14. Who Can I Contact with Questions about My PI and this Privacy Policy?

Customers located in any european country should contact Maximilian Morgenstern at M.Morgenstern@svemagroup.com.

15. Changes to Customer Privacy Policy

The effective date of each version of this Customer Privacy Policy is stated below.

We may change this Privacy Policy at any time. We will provide you with notice of a changes that impact you and an explanation of those changes.

Effective Date: July 10, 2018