Data policy declaration

 

Who are we?

This website https://emnify.com (the “Website”) is owned and operated by EMnify GmbH (called in this notice “we”, “our” or “us”). Our Imprint can be found here: https://www.emnify.com/legal

 

Purpose of this notice

This privacy notice tells you about the information we collect about you when you visit our Website or otherwise provide us with information. 

It also tells you how you can exercise Your Rights (including the right to object to some of the data handling we carry out).

 

What personal data do we collect?

Site traffic data and information about your computer

How do we use this data?

We analyse traffic on our website in order to understand our customers' requirements and, based on these, to protect our website against attacks and to continually improve our site. For this reason, we store the IP address of a visitor’s Internet Service Provider and further user-specific information such as the screen resolution and the used Operating System as standard. The IP address is not linked to a specific person. Data from individual uses of our website is stored for error analysis. We also use cookies to track visitor preferences and to improve the design of its websites accordingly.

  • Use of HubSpot

Our registration service allows visitors to our website to learn more about our company, download content and provide contact information and other demographic information. This information is stored on servers of our software partner HubSpot (www.hubspot.de). They can be used by us to contact visitors to our website and to determine which services of our company are of interest to them. All information we collect is subject to this privacy policy. We use all collected information exclusively to optimize our marketing.

HubSpot is a software company from the USA with a branch in Ireland.

Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, phone: +353 1 5187500, subject to TRUSTe's Privacy Seal and the U.S. - EU Safe Harbor Framework and the U.S. - Swiss Safe Harbor Framework.

  • Use of web analysis tool

We use a third party, Google Analytics, to collect this information but it is only processed in a way which does not identify anyone. We do not allow Google to make any attempt to find out the identities of those visiting our website.

  • Use of attribution tools – cookies and fingerprinting
    • We use this information to record visitor numbers, their use of different areas of the Website and any useful features or links. We do not use this information in any way that would identify you personally. We use services and attribution tools from third party service providers such as:
    • Google Adwords, an attribution tool for the purposes of marketing and improving our services. Google Adwords is used to collect and store data about your use of this website.
    • Double Click
    • Zendesk: Pseudonymised data is collected and stored on this website using technologies from Zendesk Inc., 1019 Market St, San Francisco, USA for the purpose of web analysis and to operate the live chat system to respond to live support requests.

These attribution tools are used to collect and store data about your use of this website and its sub-pages. This data can be used to create anonymous user profiles. For more privacy information and to manage your privacy preferences regarding Google and DoubleClick tools please go to privacy.google.com. For more information on Zendesk please visit (www.zendesk.com).

Attribution tools use technologies such as Cookies, web beacons and fingerprinting:

  • Cookies are small text files stored locally in the cache of the internet browser of the person visiting the site. You can learn more about cookies on the website allaboutcookies.org
  • Web beacons are small graphic data (also known as ‘Pixel Tags’ or ‘Clear GIFs’), which can be included in our websites, apps, applications and newsletters and are usually used in combination with cookies to identify users and user behaviour. The above-mentioned statements about cookies apply accordingly for web beacons; web beacons will in particular not be used in case you objected to the use of the relevant cookie.
  • The Fingerprinting technology stores environmental variables of your devices in a database but does not store clear user-related data such as an IP address. Cookies and/or Fingerprinting make(s) it possible to recognise your device and identify you as a user.

The data collected using the attribution tools will create personal profiles but will not be used to identify visitors by name.

You can object to the storage of your anonymous visitor data in the future via the following measures:

You can choose to opt out of this type of advertising permanently by going to http://www.networkadvertising.org/choices.

For further information about how to refuse cookies, please refer to your browser ‘Help’ section or see www.allaboutcookies.org.

Please note though, that if you delete your cookies:

  • We might no longer know that you have opted out of online behavioural advertising, so the banners from our third - party advertisers will reappear when you visit other selected websites.
  • We might no longer automatically recognise that you have agreed to our privacy policy, cookies policy and website terms and conditions and will ask for confirmation of this along with your language and country preferences.

 

  • Social media integration
    • At various places on our website we have implemented links to social media/ social networks
    • We have integrated social media tools from the following providers into our website:

Google (privacy policy)

Facebook (privacy policy)

Twitter (privacy policy)

Linkedin (privacy policy)

Please note that the primary responsibility to comply with applicable data protection law rests primarily with these providers and EMnify has only limited knowledge or influence on how social networks deal with the information they collect through their services. For more information on how these providers process personal data and your rights and options in this regard, we refer to the privacy notices of these organisations.

 

  • Information about your computer; this includes your IP address, operating system and browser type.
    • We use this information to help maintain the security of our Website and to identify trends so that we can improve its performance.
    • We also use this information to customise the Website according to your interests and to ensure the Website’s content is presented as effectively as possible for you and to enable you to participate in interactive features of the Website, when you choose to do so.
    • We do not use this information in any way that would identify you personally.

We collect this information for the purpose of our legitimate interests in maintaining and managing our Website and ensuring its security. If you do not want us to collect this information you can use your web browser’s “do not track” (“DNT”) facility to tell us that you don’t want to be tracked when you visit our Website. Further information about DNT can be found at https://allaboutdnt.com.

Additional information about how we use cookies on our Website can be found below.

How long do we keep this information for?

We will only keep information about your visit to our Website for as long as is necessary for the purposes we’ve mentioned. Typically, we delete user browsing information every 14 months.

Who do we share this information with?

We share information about visitors to our Website with service providers who help us administer and manage the Website. We also share information about your use of our Website with advertising networks, although you cannot be personally identified from this information.

Where do we transfer this information to?

Information we collect about your use of our Website is stored within, and not transferred outside of, the European Economic Area.

 

Use of Cookies

A cookie is a data file, which often includes a unique identifier, that is sent to your browser from a web server and is then stored on the hard drive of the device you are using to browse the website. Each website you visit can send its own cookie to your browser if your browser’s preferences allow it, but to protect your privacy your browser only permits a website to access cookies it has already sent to you, not cookies sent to you by other sites.

Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. Each browser is different, so check the ‘Help’ menu of your browser to learn how to change your cookie preferences. Please be aware that blocking cookies may affect the functionality of the website.

Our website makes use of the following types of cookies:

  • Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided.
  • Analytical/Performance Cookies: These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information that these cookies collect is aggregated and, therefore, anonymous. It is only used to improve how a website works.
  • Functionality Cookies: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
  • Targeting Cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
  • Social Media Cookies (as mentioned above in the section on social media integration): These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

If you wish to restrict or block the cookies which are set on the Site (or, indeed, on any other website) you can do this through your browser settings. The ‘Help’ function within your browser should tell you how.

Alternatively, visit http://www.allaboutcookies.org/ for comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer, as well as more general information about cookies.

Be aware that restricting cookies may affect your ability to navigate and use our Website.

 

Information you send us

How do we use this data?

You do not have to supply us directly with any information when you use our Website. If you choose to use our ‘contact us’ feature or otherwise get in touch with us, we will use the information you send us for the purpose of responding to your enquiry. When we use your personal data for this purpose, we do so for our legitimate business interest in communicating with you in accordance with your wishes and expectations. We will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.

For more information about how we use information you send us for recruitment purposes see our section on https://breezy.hr/privacy

How long do we keep this information for?

We will only keep your information for as long as is necessary in order to manage your query. We usually keep records of routine queries for 6 months but in some cases (for example where the query relates to a contract between us, or where we need to obtain legal advice in order to respond to a complaint) we may need to retain a record of our communications for up to 3 years.

Who do we share this information with?

We will share your data with our service providers and our professional advisers if this is necessary in order to resolve a query or complaint.

Otherwise we will not share your information with any third party unless:

  • we have your permission;
  • we are required to do so by law;
  • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Where do we transfer this information to?

Information you send us via our Website is stored within, and not transferred outside of, the European Economic Area.

 

Recruitment

How do we use this data?

We use information you supply in support of your application so that we can consider your application, assess your suitability, and conduct eligibility checks where necessary and to the extent permitted by law.

We use your data for the purpose of our legitimate interests in managing our recruitment and so that we can take steps at your request prior to entering into a contract. If a position that is, or may be, of interest to you, requires background checks, we will tell you about this.

Where necessary, we will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.

When you apply for a position with us, or submit information in support of your application, we will tell you whether the information we are requesting is essential so that we can progress your application or whether the supply of this information is optional.

With the exception of personal data which we collect and use for the purpose of entering into a contract with you, you can object to our use of the data you have provided at any time.

How long do we keep this information for?

We usually retain information supplied by job applicants for no longer than 6 months following a relevant recruitment decision. If your application is unsuccessful, we may decide to retain your details for longer if we think you may be suitable for another position that may arise within EMnify GmbH in the future but we will only do this if you agree.

If your application is successful, relevant information will be used for the purpose of administering your subsequent employment and will be retained and used in accordance with our employee privacy notice (a copy of which will be provided when you take up your employment).

Who do we share this information with?

Where necessary so that we can manage our recruitment process, we will share your information with our service providers and professional advisers (e.g. recruitment agencies, providers who carry out background checks on our behalf, and if applicable to the role you are applying for, suppliers who run online testing for us). If we have a reasonable interest in verifying the data you have provided (e.g. if there are indications that they are incorrect) and we have no other means to check this, we will also contact third parties whose details you have supplied so that we can verify information you have supplied in relation to your previous employment and qualifications.

Our recruitment site is operated by BreezyHR, a third-party company based in the USA and with a data centre in Germany, which supplies personnel management and applicant management software (https://breezy.hr/privacy ). The data provided as part of your application is transferred using TLS encryption and stored at the data centre in Germany. In accordance with Article 24 GDPR, we as the company carrying out this online application process are solely responsible for this data. BreezyHR is simply the operator of the software and this recruitment site, and, in this context, is the processor within the meaning of Article 28 GDPR. BreezyHR carries out this processing on the basis of a processing contract with us. BreezyHR also processes other data, which may, in part, be personal data, for the provision of its services, in particular the operation of this recruitment site.

Otherwise we will not share your information with any third party unless:

  • we have your permission
  • we are required to do so by law;
  • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • this is subject to applicable laws necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Where do we transfer this information to?

Information you send us in support of your employment application via our recruitment site is held by our service provider BreezyHR on secure servers located outside the European Economic Area (EEA) in the United States. BreezyHR is registered with the EU-US Privacy Shield. If you require further information about these safeguards, please visit https://www.privacyshield.gov

 

Information you give us when you sign up for our newsletter or sign up as site user

How do we use this data?

You do not have to supply us directly with your personal data when you use our Website. However, some communications, services and facilities can only be provided if you supply us with relevant details. For example, if you sign up for our newsletter or sign up as a site user you will be asked to provide us with your contact details. If we ask you to supply us with information that is not strictly necessary in order for us to provide you with the communication, service or facility you are interested in, we will make this clear. This might be because it is useful to us in helping us learn more about our customers or enhance our products and services.

If you do sign up for our newsletter or set up an online account we will use the personal data you provided:

  • to provide you with newsletters and other promotional information that you request from us;
  • to manage your online account;
  • to improve our understanding of the needs and interests of our customers and contacts; and
  • to notify you about changes to our services.

When we use your personal data for these purposes, we do so for our legitimate interests in managing and administering online accounts and for our legitimate business interests in developing and promoting our goods and services and communicating with you in accordance with your wishes and expectations. You can object to our use of your data for these purposes at any time. For further information about the way we use your data for direct marketing purposes see our direct marketing section. We will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject.

How long do we keep this information for?

Information we hold for the purpose of managing your online account or profile is held by us for as long as your account or profile continues to be active.

Information we hold for market research purposes is not usually held in a form that will identify you for longer than 14 months.

Information we hold for direct marketing purposes so that we can send you newsletters and other promotional material is held by us for as long as you continue to be interested in receiving our marketing communications. However, you can tell us to stop using your details for marketing purposes at any time by contacting us.

Who do we share this information with?

We share this data where necessary with our suppliers, service providers and professional advisers.

Otherwise we will not share your information with any third party unless:

  • we have your permission;
  • we are required to do so by law;
  • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • this is subject to applicable laws necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Where do we transfer this information to?

Information we collect when you sign up for our newsletter, or set up an online account or profile is stored within, and not transferred outside of, the European Economic Area.

 

Direct Marketing

How do we use this data?

We will use contact details you give us to deliver promotional information that you request or that we feel may interest you. We will also use this information to gain insights into the needs and interests of our customer base and to evaluate the effectiveness of our marketing activities.

We will only contact you for marketing purposes by email if you have consented to this.

When we use your data for our direct marketing purposes we do so for our legitimate interests in promoting our business and the services we offer.

How long do we keep this information for?

We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications. We use tracking technology to help us monitor the effectiveness of our e-marketing and delete contacts from our e-marketing database after 2 years of recipient inactivity.

You can tell us to stop using your details for marketing purposes by contacting us and can opt out of email marketing at any time by using our unsubscribe feature

Who do we share this information with?

Where necessary we share this data with our suppliers and service providers.

Otherwise we will not share your information with any third party unless:

  • we have your permission;
  • we are required to do so by law;
  • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • this is (subject to applicable laws) necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Where do we transfer this information to?

Information we hold for direct marketing purposes is stored within, and not transferred outside of, the European Economic Area.

 

Use of our Blog

How do we use this data?

In our blog, where we publish various articles on topics related to our activities, you can make public comments. Your comment will be published with your username. We recommend that you use a pseudonym instead of your clear name. User name and E-mail address are required, all other information is voluntary.

How long do we keep this information for?

When you make a comment, we continue to store your IP address, which we delete after one week. The storage is necessary for us to be able to defend ourselves against liability claims in cases of possible publication of illegal content. We need your e-mail address in order to contact you if a third party should object to your comment as unlawful. The legal basis is Article 6 (1) lit. b and lit. f GDPR. Comments will not be reviewed before publication. We reserve the right to delete comments if they are objected to as unlawful by third parties.

Who do we share this information with?

Where necessary we share this data with our suppliers and service providers.

Otherwise we will not share your information with any third party unless:

  • we have your permission;
  • we are required to do so by law;
  • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or
  • this is (subject to applicable laws) necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners).

Where do we transfer this information to?

Information we hold for direct marketing purposes is stored within, and not transferred outside of, the European Economic Area.

 

Your Rights

You can ask us at any time to provide you with a copy of your personal data. In relation to personal data you have supplied to us, and which is held by us for the purpose of entering into a contract between us or on the basis of your consent, you are entitled to ask us for a copy of this information in a structured, commonly used and machine-readable format so that you can reuse it or share it with other organisations.

If you think the personal data we hold about you is inaccurate or incomplete, you can ask us to correct it or complete it.

In some circumstances you also have the right to object to our processing of your data and can ask us to restrict our use of your data and to delete it.

If we ask for your consent so that we can use your data for a particular purpose, you are free to withdraw your consent at any time and we will tell you how you can do this.

There are some exceptions to these rights, however. For example, it will not be possible for us to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.

If you wish to exercise any of these rights, you should contact us.

 

Contacting us and your rights of complaint

Questions, comments or requests concerning this privacy notice are welcomed and should be addressed to info@emnify.com. If you have a concern about the way we handle your personal data, you have the right to complain to the Data Protection Authority of Bavaria for the private sector (Bayerisches Landesamt für Datenschutzaufsicht). You can find details of how to do this on their website at https://www.lda.bayern.de/de/beschwerde.html.

 

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This privacy notice was last updated on August 2018.