Elmo Date Privacy Notice

Protecting the security and privacy of your personal data is important to Elmo. Therefore, Elmo processes personal data in compliance with applicable laws on data protection and data security.

 

  1. Processing of personal data related of your personal use of Elmo Online Platforms

When visiting Elmos’ websites, applications or online tools (“Elmo Online Platforms”), Elmo may process the following personal data about you:

  • Personal data that you actively and voluntarily provide via the Elmo Online Platforms (e.g., when registering, contacting us with your inquiries or participating in surveys, etc.), including name, e-mail address, telephone number, information submitted as part of a support request, comments or forum posts, etc.; and
  • Information that is automatically sent to us by your web browser or device, such as your IP-address, device type, browser type, referring site, sites accessed during your visit, the date and time of each visitor request.

We process your personal data for the following purposes:

  • To provide the Elmo Online Platforms services and functions and to administer your use of the Elmo Online Platforms;
  • To verify your identity (if you registered for a Elmo Online Platforms);
  • To answer and fulfill your specific requests; and
  • As reasonably necessary to enforce the applicable terms of use, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on Elmo information technology systems.

The legal basis for Elmo processing data about you is that such processing is necessary for the purposes of:

  • Elmo exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation);
  • Compliance with Elmo’s legal obligations (Article 6 (1) (c) General Data Protection Regulation); and/or
  • Legitimate interests pursued by Elmo (Article 6 (1) (f) General Data Protection Regulation). Generally the legitimate interest pursued by Elmo in relation to our use of your personal data is the the efficient performance or management of your use of the Elmo Online Platforms.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for Elmo processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

 

Links to other websites

This Privacy Notice applies only to Elmo Online Platforms and not to other websites or applications operated by third parties. We may provide links to other websites and applications which we believe may be of interest to you. Elmo is not responsible for the privacy practices of such other websites or applications.

 

  1. Processing of personal data related to your business relationship with Elmo

 

In the context of the business relationship with Elmo, Elmo may process the following categories of personal data of current and future contact persons at our customers, suppliers, vendors and partners (each a “Business Partner”):

  • Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address;
  • Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
  • Further information necessarily processed in a project or contractual relationship with Elmo or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones;
  • Personal data collected from publicly available resources, integrity data bases and credit agencies; and
  • If legally required for Business Partner compliance screenings: date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners.

Elmo may process the personal data for the following purposes:

  • Communicating with Business Partners about products, services and projects of Elmo or Business Partners, e.g. by responding to inquiries or requests or providing you with technical information about purchased products;
  • Planning, performing and managing the (contractual) relationship with Business Partners; e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
  • Administrating and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests, or other promotional activities or events;
  • Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities;
  • Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and Elmo policies or industry standards; and
  • Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims.

The legal basis for Elmo processing data about you is that such processing is necessary for the purposes of:

  • Elmo exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
  • Compliance with Elmo’s legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or
  • Legitimate interests pursued by Elmo (Article 6 (1) (f) General Data Protection Regulation).

Generally the legitimate interest pursued by Elmo in relation to our use of your personal data is the efficient performance or management of our business relationship with you.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for Elmo processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

  1. Transfer and Disclosure of personal data

 

 

Elmo may transfer your personal data to:

  • other Elmo companies in connection with your use of the Elmo Online Platforms or our business relationship with you;
  • third parties which provide IT services to Elmo and which process such data only for the purpose of such services (e.g., hosting or IT maintenance and support services); and
  • courts, arbitration bodies, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of rights or legal claims.

Sometimes the recipients to whom Elmo transfers your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country.

In such cases, Elmo takes measures to implement appropriate and suitable safeguards for the protection of your personal data. In particular:

Personal data published by you on Elmo Online Platforms (such as chat rooms or forums) may be globally accessible to other registered user of the respective Elmo Online Platforms

 

 

  1. Retention Period

Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary (i) for the purposes for which they were collected or otherwise processed, or (ii) to comply with legal obligations (such as retention obligations under tax or commercial laws).

 

  1. Withdraw consent

In case you declared your consent for the processing of certain personal data by Elmo, you have the right to withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, Elmo may only further process the personal data where there is another legal ground for the processing.

 

  1. Your rights

 

Under applicable data protection law you may have the right to:

  • Obtain from Elmo confirmation as to whether or not personal data concerning you are being processed, and where that is the case, access to the personal data;
  • Obtain from Elmo the rectification of inaccurate personal data concerning you;
  • Obtain from Elmo the erasure of your personal data;
  • Obtain from Elmo restriction of processing regarding your personal data;
  • Data portability concerning personal data, which you actively provided; and
  • Object, on grounds relating to your particular situation, to processing of personal data concerning you.

 

 

The Elmo Data Protection Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights. The Elmo Data Privacy Organization may be contacted at: dataprotection@elmomc.com.

 

The Elmo Data Privacy Organization will always use best efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the Elmo Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.