Privacy Statement

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.

What is Personal Data?

“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.

Data transmitted across euNetworks’ network

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.

What kind of Personal Data does euNetworks hold about External Individuals

The types of Personal Data that you are likely to provide to us in respect of External Individuals are as follows:

  • names;
  • telephone numbers;
  • email addresses; and
  • other contact details.

Other Personal Data may be required in limited circumstances, for example to arrange entry to datacentres or other locations.

How does euNetworks collect your Personal Data?

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.

How is Personal Data used?

euNetworks may use Personal Data to:

  • process customers’ orders, suppliers’ orders or similar order types;
  • negotiate or fulfil our obligations arising from any contract or relationship entered into by euNetworks with you;
  • notify External Individuals of any changes to our services as requested by you;
  • send External Individuals marketing communications which they have subscribed for on a marketing mailing list. These communications may include information about campaigns, events and our services;
  • understand what services we may be able to provide to you or you may be able to provide to us; and
  • Management of our companies and reporting obligations.

Who has access to your personal information?

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.

How you can access and update your personal information?

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.

What are the legal rights relating to Personal Data?

Subject to the GDPR, the External Individuals’ legal rights are:

  • the right of information;
  • the right to rectification or cancellation;
  • the right to restriction of processing;
  • the right to data portability;
  • the right to object to the Processing of Personal Data;

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.

Security precautions in place to protect the loss, misuse or alteration of your information?

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.

Transferring Personal Data outside of Europe

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.

How long will euNetworks keep your Personal Data?

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.

Processing of Personal Data on our websites www.eunetworks.com and www.eunetworks.de

Controller
euNetworks is a company group in which certain departments and tasks are shared between different companies in the group. The department responsible for the operation of this website is shared between the euNetworks GmbH, Theodor-Heuss-Allee 112, 60486 Frankfurt and euNetworks Holdings Limited, 5 Churchill Place , London E14 5HU, United Kingdom (both jointly “euNetworks”) which act as joint controllers according to Art. 4 No. 7 and Art. 26 GDPR. Both companies comply with GDPR requirements and you can reach out to either one of them in case of any questions or inquiries. We also refer to our legal notice, available at eunetworks.com/legal-notice/ or eunetworks.de/impressum/

  1. 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:
  • date and time of access to one of our websites;
  • browser type;
  • browser settings;
  • operating system used;
  • page you last visited;
  • amount of data transferred and the access status (file transfer, file not found etc.); and
  • IP address.

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. The processing is based on our legitimate interests.

  1. 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. We have a legitimate interest (direct advertising) in advertising customers (persons with whom we have had a business relationship) by e-mail or post. In particular, we may send you news about our company or group companies, information on events and invitations to review our services and products. You can object to the sending of advertising at any time by sending an e-mail to our data protection officer or by following the instructions at the end of a promotional e-mail. If possible, please send your e-mail from the same e-mail address you used for registration, so that we can assign you more easily.
  2. 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. The processing is lawful because it is necessary for the performance of the contract.
  3. Contact forms and e-mail inquiriesOur contact forms provide you with the opportunity to contact us. If you provide Personal Data, we will process it as set out above. In order to process your request, we process names, e-mail addresses, possibly the names of your company, position, mandatory information, which are absolutely necessary to create an offer. The processing of your data in the context of contact made by e-mail, a contact form or by telephone takes place on the basis of our legitimate interest to provide a good customer service or is necessary to fulfil a contract or to process operations necessary for the implementation of pre-contractual measures insofar as the contacts are related to contractual performance obligations. We will delete your contact requests immediately after processing unless statutory retention periods require continued retention. After answering your inquiry, we will archive your request immediately. Access is only possible to a very limited extent. Solely informative inquiries, i.e. which do not result in a contract or do not contain any other content that needs to be retained, will be deleted at the end of the year in which the request was made.
  4. Security and Performance: Google reCAPTCHA We use Google reCAPTCHA to prevent automatic programs/bots from using our contact form. This increases the security of our website and avoids SPAM. This is also our legitimate interest and fulfils our legal obligation. The collected data is hardware and software information, e.g. device and application data as well as the results of security checks. This data is transmitted to Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data will not be used for personalised advertising. Further information can be found in Google’s privacy policy at https://policies.google.com/privacy. Further documentation can be found at https://developers.google.com/recaptcha/ and at https://www.google.com/recaptcha/admin/create.
  5. Fonts and other embedded third-party content
  6. a) Google Fonts This website uses Google Fonts of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Holding Company: Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA). These fonts are automatically optimised for the web and there save data traffic and result in quicker loading times. The legal basis is formed by our legitimate interests in the efficient and secure provision of the website. Insofar as Google Ireland Limited transfers personal data to the US parent company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, Google guarantees by means of standard contractual clauses to maintain the EU level of data protection.
  7. b) Font Awesome This website uses Font Awesome, to embed fonts and icons into the website to make our website more visually attractive. For this purpose we use the processor Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA. Further information on data protection can be found at https://fontawesome.com/privacy. The legal basis is formed by our legitimate interests in the efficient and secure provision of the website. Font Awesome guarantees by means of standard contractual clauses to maintain the EU level of data protection. Next to this data, every Font Awesome request also automatically transmits data like your IP-address, language settings, screen resolution, name, and version of your browser to the Font Awesome Servers. This is necessary to ensure a correct graphical display.
  8. Cookies, web analysis and marketing tools In some cases, we or our partners use cookies or process your data in such a way that your consent is required. Cookies are small text files that can be stored on your device when you visit our website. Tracking is possible using various technologies like the pixel technology or log file analysis. Consent is given via the so-called consent manager, which must be actively clicked. Our cookie policy explains how you can disable individual functions to which you have consented. There you will find information on when cookies expire, how to delete cookies and how to withdraw your consent.

Unless otherwise stated, the processing described in this section is based on your consent. Learn more about how to withdraw your consent in our Cookie Policy. Our cookie policy is linked in the footer of our website.

  1. Web-Analytics, Statistics
    To determine which content from our website is most interesting for you we continuously measure the number of visitors and the most viewed content. Therefore, we process your personal data
  • to record the number of visitors of our websites,
  • to record the respective visiting times of our website visitors and
  • to record the sequence of visits to different websites and product sites to optimise our website.

(1) Google Analytics This website uses Google Analytics of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Holding Company: Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA) to analyse the usage of our web services. The collected data is used to optimise our website and our advertising effort. Google Analytics is a web-analysing-service provided by Google. Google processed this data on our behalf and is contractually bound to implicate measures to ensure the integrity and confidentiality of the data.

Upon visiting our website, the following data is processed:

  • IP-address (in a shortened form. User cannot be directly identified)
  • Approximate location (country and city)
  • Technical information like browser, internet provider, device and screen resolution
  • User behaviour (accessed pages, clicks and scroll-behaviour)
  • Orders including the revenue of the ordered products
  • Origin of your visit (from which website or which advertisement our site was reached)
  • Session length and if the site was left without any interaction
  • Adding to favourites
  • Sharing of content (social media)

The legal basis is your consent. Upon the first visit to our website, we ask for your consent. Consent may be withdrawn at any time. This can be done by using our consent manager or by deleting the cookies in your browser. Another possibility is the browser addon provided by google, which deactivates Google Analytics. You can download it here: https://tools.google.com/dlpage/gaoptout?hl=dehttps://tools.google.com/dlpage/gaoptout?hl=de

Insofar as Google Ireland Limited transfers personal data to the US parent company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, Google guarantees by means of standard contractual clauses to maintain the EU level of data protection. Google Analytics sets cookies in your browser for the duration of two years from your last visit. These cookies contain a randomly generated User-ID, with which you can be recognised upon your next visit. The recorded data is stored in combination with the randomly generated User-ID, which makes an analysis of pseudonymised user profiles possible. This data will be automatically deleted after 14 months. Other data is stored in aggregated form indefinitely.

(2) Google Tag Manager Together with Google Analytics we use the Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Holding Company: Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA). The Tag Manager allows us to place and administrate small code elements called “tags” via an interface. The tool itself does not process any personal data itself. Google Tag Manager enables the activation of tags, which allows other services to collect data, but does not access the data itself.

Further information about the Google Tag Manager can be found here: https://www.google.com/intl/de/tagmanager/faq.html

(3) Hotjar This website uses Hotjar (Service Provider: Hotjar Ltd, St Julians Business Centre, Elia Zammit Street 3, St Julians STJ 3155, Malta, Europa), to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

The legal basis is your consent. Upon the first visit to our website, we ask for your consent. Consent may be withdrawn at any time. This can be done by using our consent manager or by deleting the cookies in your browser. According to Hotjar, the data will only be retained for as long as is necessary for the purpose(s) for which we originally collected it or as required by law. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see https://www.hotjar.com/legal/policies/privacy/.

b) Online advertising based on Tracking and Retargeting

We would like to show you – also on the websites of our advertising partners – only advertising that really interests you. Therefore, we use the technologies of so-called tracking and retargeting on our website for advertising that is tailored to your interests. Cookies are usually used for this purpose, but other technologies such as so-called “fingerprinting” are also used in some cases. The cookies temporarily stored for this purpose enable our retargeting partners to recognise visitors to our website under a pseudonym and to display only products that are likely to interest you. Fingerprinting recognizes your device based on your computer hardware, software, add-ons and browser settings.

Unless otherwise stated, the processing described in this section is based on your consent. Learn more about how to withdraw your consent in our cookie policy. There you will find information on when cookies expire and how to delete cookies. Our cookie policy is linked in the footer of our website.

In detail, we use the data collected for statistical and advertising purposes

  • for targeted advertising, also via advertising networks in cooperation with partners,
  • to measure the success and billing of advertising measures between advertising partners and us,
  • to keep track of what ads you have already seen to prevent you from seeing the same one again and
  • to assess which parts of our website need to be optimised.

Unless otherwise stated, we use the following services as processors and contractually oblige them to process data only on our behalf.

(1) Google DoubleClick DoubleClick by Google (“DoubleClick”) is a service by Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). DoubleClick uses cookies to display most relevant advertisements. Google keeps track of the advertisements you have seen and which of them you have actually viewed. Using the DoubleClick cookies allows Google and its advertising network to serve advertisements based on your previous web page visits (or even apps). Google will transmit information generated by the cookies to a Google server for analysis and storage. You can prevent cookies from being saved by setting your browser software accordingly.

For more detailed information on the terms and conditions of use and data protection, please visit: https://www.google.com/analytics/terms/de.html or https://www.google.com/intl/de/analytics/privacyoverview.html.

(2) Google Ads We use Google Ads, an ad service by Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), and also conversion tracking as part of Google Ads. Google Ads stores a conversion tracking cookie on your computer’s hard drive (“conversion cookie”) when you click on an advertisement placed by Google. If you visit certain pages of our website, Google can recognise that you have clicked on the advertisement and were referred to this web page.

The information obtained using conversion cookies is used to generate statistics for Ads customers who use conversion tracking. These statistics show us the total number of users who clicked on the Google advertisement and viewed a web page with a conversion tracking tag.

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.

How does euNetworks safeguard transfers to third countries?

In the case that your data is transferred to third countries either to Controllers or Processors, the transfer is justified by the EU Standard Contractual Clauses according to the Annex of the Commission Decision 2021/914/EU and/or by concluding International Data Transfer Agreements provided by the ICO. With regard to transfers between the European Union and the United Kingdom, we refer to the adequacy decision of the European Union.

Who to contact if you have any concerns?

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) Colmantstr. 15, 53115 Bonn, Germany Email: dataprotection@eunetworks.com or datenschutz@eunetworks.com This Privacy Statement was last reviewed and updated in September 2022.