DATA PRIVACY NOTICE FOR OUR CUSTOMERS, OUR SUPPLIERS AND OTHER THIRD PARTIES This Data Privacy Notice (“Notice”) describes how euNetworks Group Limited and its group entities and subsidiaries (available at eunetworks.com/companies/ or eunetworks.de/firmeninformation/) (“euNetworks” or “us” or “our”) collects and uses Personal Data provided by our customers, our suppliers and other third parties (“you” or “your”) about individuals (“External Individuals”), during and after our business relationship with euNetworks, in accordance with the General Data Protection Regulation (GDPR).euNetworks Group Limited and its entities and subsidiaries act as controllers for the purposes of this Notice. This Notice does not form part of any contract (such as a Master Services Agreement, Customer Order, supplier order) between euNetworks and you. We may update this Notice at any time but if we do so, we will provide you with an updated copy of this Notice on our website as soon as reasonably practical. euNetworks usually contracts with businesses and those businesses will provide us with Personal Data about individuals within their organisations (External Individuals). We assume that you are providing consent for us to collect and process External Individuals’ Personal Data in accordance with this Notice or, that as an External Individual, you provide this consent. It is important that you read and retain this Notice and pass it on to any External Individuals in respect of whom we are collecting or processing Personal Data, so that you and they are aware of how and why we are using such information and what their rights are under the data protection legislation. We have a separate Privacy Policy in respect of individuals who work for euNetworks and this Notice does not apply to them.
“Personal Data” is any information related to a “real” person that can be used to directly or indirectly identify the person. This includes Personal Data in a business context, such as work telephone numbers, or email addresses that are tied to individuals.
euNetworks is a provider of bandwidth infrastructure services. We focus on delivering scalable, fibre-based products and solutions. When our customers use our services, the data that they transmit is not in a form that allows any individuals to be identified. Accordingly, notwithstanding the underlying content of that data, no Personal Data is processed by us. We will not take any steps to identify any individuals whose data is contained in the data transmitted by or customers. Accordingly, we are not a data controller or data processer in respect of this data (even if it includes Personal Data) and such data is not within the scope of this Notice. When you provide Personal Data relating to External Individuals to us so that we can provide services to you, use your services or otherwise undertake business with you, we have a legitimate business interest in processing that Personal Data and also consider that you have provided consent on behalf of such External Individuals for us to do so.
The types of Personal Data that you are likely to provide to us in respect of External Individuals are as follows:
Other Personal Data may be required in limited circumstances, for example to arrange entry to datacentres or other locations.
euNetworks collects and obtains Personal Data about External Individuals when this data is provided to us in the course of our business. This may include when you contact us by email or telephone, when you provide contact details in a contract, when you register to use our portal or when you meet with us. External Individuals may also sign up to receive newsletters or other contact from us.
euNetworks may use Personal Data to:
euNetworks and such subcontractors as are required to contact External Individuals have access to Personal Data as is required to enable them to assist us in providing our services. We do not provide Personal Data to third parties for any other reason.
The accuracy of all information is important to euNetworks. If any of the Personal Data provided changes, please advise us and we will update this. If you have questions over the Personal Data held, please ask us.
Subject to the GDPR, the External Individuals’ legal rights are:
You also have the right to complain to a data protection supervisory authority about the processing of your Personal Data by euNetworks. In some cases, it will be necessary to provide evidence of identity before we can give effect to these rights. These rights are subject to our rights to retain data as required to run our business and to comply with our obligations. If any of your External Individuals withdraw consent to use their Personal Data, you will need to provide us with alternative contact details.
When External Individuals give euNetworks Personal Data, euNetworks take steps to ensure that it’s treated securely. euNetworks has implemented technical and organisational security measures to ensure the compliance of security of Personal Data under GDPR and to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing. The details of your user account are protected by a password for this purpose. In all sensitive areas, SSL encryption technology is used in the transmission of data. If you wish to contact euNetworks via e-mail, we point out that the confidentiality of the transmitted information cannot be guaranteed. The content of emails can be viewed by third parties. It is therefore advisable to provide confidential information only by post.
In providing services to you, it may from time to time be necessary for us to transfer Personal Data to partners outside the European Economic Area (“EEA”). External Individuals’ rights will not be affected by this and euNetworks will take all reasonable steps to ensure that all Personal Data transferred outside the EEA is treated in accordance with this Privacy Notice and with the same level of protection required by data protection legislation (for example by using EU Standard Model Clauses). By providing us with Personal Data you accept that you have no objection to such transfer, processing or storage.
euNetworks keeps Personal Data for no longer than is necessary for the business purposes for which the Personal Data is processed. This means we will delete Personal Data from our IT systems after the relevant business relationship ends and the period for which we are required to hold information expires. If an External Individual unsubscribes from our mailing list, we will remove their details immediately.
1. Responsibility The euNetworks company formally responsibility for the operation of our website is explained in our legal notice, available at eunetworks.com/legal-notice/ or eunetworks.de/impressum/ 2. Server-log files Use of our websites does not generally require you to provide Personal Data. We do collect and use the data that your Internet browser provides to us. This includes:
We store this data on our servers. We use this data and store log-files to deliver our website to you, to ensure the security of our information technology systems, to review use of our website and to improve our products and services. We do not use this data for marketing purposes and delete log-files within 7 days. 3. Registration When you register to use euNetworks products or online services, you will be asked for certain personal information. If you provide Personal Data, it will be processed as set out above. 4. Online map information LISA (Line Information Service App) You can obtain information about the location of our network through the online service “Online Information Sheet LISA (Line Information Service App)”. This requires a registration including Personal Data which we will process as set out above. Your Personal Data will be stored by us until you delete your registration through the log-in area or tell us you would like us to delete it, which you can do by e-mail. 5. Contact forms and e-mail inquiries Our contact forms provide you with the opportunity to contact us. If you provide Personal Data, we will process it as set out above. 6. Cookies, web analysis and integrated offers of third parties We use cookies on our websites. Cookies are small text files that are sent from our web server to your browser as part of your visit to our website and are held by this on your computer for later retrieval. We only use session cookies (also referred to as temporary cookies), which are cookies that are only cached for the duration of your use of one of our Internet pages. The purpose of these cookies is to continue to identify your computer during a visit to our website when switching from one of our websites to another of our websites and to be able to determine the end of your visit. The cookies are deleted as soon as you finish your browser session. Whether cookies can be set and retrieved can be determined by the settings in your browser. For example, you may disable your cookie altogether, restrict it to certain websites, or configure your browser to automatically notify you when a cookie is about to be placed and ask for your feedback. For technical reasons full functionality of our websites requires the use of session cookies. 1 . a) Use of Google Analytics Our website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics also uses Cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Google Analytics has been extended by “anonymizeIp” to ensure an anonymous collection of IP addresses (so-called IP-Masking). By activating IP anonymisation on our website, your IP address will be truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area (EEA). Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google will use this information to evaluate your use of our website, to compile reports on website activity and to provide other services related to website activity and internet usage to us. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by using the link below (tools.google.com/dlpage/gaoptout?hl=en) to download and install the available browser plugin. Further information at: google.com/analytics/terms/gb.html or google.com/analytics/terms/de.html or google.com/intl/de/analytics/privacyoverview.html. 1 b) Social Media Services und Plugins We do not use direct plug-ins from social networks on our websites and your use of social networks is governed by their terms.
Formal compliance with GDPR is undertaken by euNetworks Group Limited and our local subsidiaries (see eunetworks.com/companies/ or https://www.eunetworks.de/firmeninformation/) also take responsibility. The aforementioned bodies shall jointly determine the purposes and means of processing. You can also see our legal notices: eunetworks.com/legal-notice/ or eunetworks.de/impressum/. If you have any questions about this Notice or how we handle your Personal Data, please contact our Data Protection Officer: RICKERT Rechtsanwaltsgesellschaft m.b.H. (i.e. law firm)Kaiserplatz 7 – 9, 53113 Bonn, Germany Email: dataprotection@eunetworks.com or datenschutz@eunetworks.com This Privacy Statement was last reviewed and updated in May 2018.