Categories of data, purpose of processing and legal basis
In the course of our collaboration with business partners, Siekmann Econosto processes personal data of contact persons at customers, potential clients, sales partners, suppliers and partners (each referred to as a “business partner”):
− Contact information, such as first name and surname, business address, business telephone number, business mobile number, business fax number and business e-mail address
− Payment data, such as data necessary for processing payments and fraud prevention, including credit card numbers and card security codes
− other information, the processing of which is necessary in the context of a project or the handling of a contractual relationship with SE or which is provided voluntarily by business partners, for example in the context of orders, enquiries or project details
− Personal data collected from publicly available sources, information databases or credit agencies
− If legally required for compliance screenings: date of birth, ID numbers and identity cards, and information about relevant litigation or other legal proceedings involving business partners.
Siekmann Econosto processes the personal data for the following purposes:
− Communicating with business partners about our products, services and projects, for example by responding to enquiries or requests, or providing technical information about products
− Planning, performing and managing the (contractual) relationship between SE and business partners, for example 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;
− Conducting customer surveys, marketing campaigns, market analyses, prize draws, competitions or similar campaigns and events
− Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities
− Compliance with (i) legal requirements (e.g. tax and commercial retention obligations), (ii) existing obligations to conduct compliance screenings (to prevent economic crime or money laundering) and (iii) SE and Group policies and industry standards
− Settling disputes, enforcing contractual agreements and establishing, exercising or defending legal claims
The processing of the personal data is necessary in order to achieve the above-mentioned objectives. Unless expressly stated otherwise at the time of collection of personal data, the legal basis for data processing is:
− the execution and fulfilment of a contract with you (Article 6 (1) (b) of the General Data Protection Regulation)
− the fulfilment of legal obligations to which Siekmann Econosto is subject (Article 6 (1) (c) of the General Data Protection Regulation); or
− the protection of the legitimate interests of Siekmann Econosto (Article 6 (1) (f) of the Basic Data Protection Regulation). The legitimate interest of SE lies in the initiation, implementation and handling of the business relationship.
In some cases we expressly ask you for your consent to the processing of personal data. In such cases, the legal basis for the processing of personal data is the consent given by you (Article 6 (1) (a) of the Basic Data Protection Regulation).
If, in individual cases, you have given your express consent to the processing of your personal data, this consent is the legal basis for the subsequent processing of the data (Article 6 (1) (a) of the Basic Data Protection Regulation).
Categories of data, purpose of processing and legal basis
When visiting Siekmann Econosto’s websites, applications or online tools (each a “SE Online Offering”), SE may process the following personal data about you:
In the context of your use of Siekmann Econosto websites, applications and online platforms (each referred to as an “SE Online Offer”) SE processes the following personal data:
− Information that is automatically sent to us from your web browser or end device, for example your IP address, device type, browser type, previously visited website, sub-pages visited or the date and time of the respective visitor request and
− Personal data that you enter voluntarily as part of an SE Online offering (for example, when registering, requesting contact or participating in surveys etc.), such as your first name and surname, email address, telephone number, information provided as part of a support request, comments or forum posts.
We process your personal data for the following purposes:
− to allow you to make use of the services and features of the SE Online offerings,
− to establish your identity and enable user authentication,
− to process your request or enquiry, and
− to enforce our terms and conditions of use, to assert or defend against legal claims, and to defend and prevent fraudulent or similar acts, including attacks on our IT infrastructure.
The processing of personal data is necessary in order to achieve the stated purposes. Unless expressly stated otherwise when collecting personal data, the legal basis for data processing is:
− the execution and fulfilment of a contract with you (Article 6 (1) (b) of the General Data Protection Regulation),
− the fulfilment of legal obligations to which Siekmann Econosto is subject (Article 6 (1) (c) of the General Data Protection Regulation), or
− the protection of the legitimate interests of Siekmann Econosto (Article 6 (1) (f) of the Basic Data Protection Regulation. The legitimate interest of SE lies in the processing of your personal data for the purpose of offering and operating the SE online offerings.
In some cases, we explicitly request your consent to the processing of your personal data. In this case, the legal basis for the processing of personal data is the consent you have given (Article 6 (1) (a) of the General Data Protection Regulation).
Links to other websites
This data protection statement only applies to SE online offerings and not to third-party websites and applications. SE online offerings may contain links to third-party websites and applications that may be of interest to you. Siekmann Econosto is not responsible for the collection, processing and use of your data in the context of websites or applications that are not operated by SE or for their content.
On our website we use a link to our Facebook fan page. Jointly responsible for the operation of our Facebook fan pages is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The data protection officer can be reached via the contact form or by post at the above address. Facebook Inc, is the American parent company of Facebook Ltd.
The purpose and legal basis of processing data
You can access our social media fan pages regularly at any time on the Internet, regardless of whether or not you have created a user account on the platform in question. If you are logged in to your facebook account, facebook can assign this to your facebook account. In both cases, however, your data will be processed by the internet platforms of the social network. Every time you access the social media platform, your IP address is recorded and saved. In addition, a cookie is usually set on your site, which stores your visit and other data about your visit to the social media platform. Please note that we have no influence on the collection of data and its further use by the social networks. For example, there is no knowledge of the extent to which, where and for how long the data is stored, to what extent the networks comply with existing deletion obligations, what evaluations and links are made with the data and to whom the data is passed on. When calling up our facebook fan pages, your data will be transferred to the USA.
Contact requests and visitor activity
If you contact us through facebook messenger to inform yourself about our services or to share your feedback, we process your personal data on the basis of our legitimate interest in responding to your request in accordance with Article 6 Para. 1 f) GDPR and, if applicable, Article 6 Para. 1 b) GDPR, if your request is aimed at the conclusion of a contract. Usually, we receive the following data from you:
− name, first name,
− age, place of residence (if they are public),
− information that you provide in your message or comment to us,
− if you have responded to our post and type of response, or you have shared or commented on it.
The data will be deleted as soon as they are no longer required for the purpose of their collection and no legal obligations to retain them exist. For the personal data from Facebook messages, this is the case when the respective conversation with the user has ended. The conversation ends when it is clear from the circumstances that the matter in question has been finally clarified.
Our website makes use of functions from the LinkedIn network. The provider here is LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland. Each time that you access one of our sites, which contains the LinkedIn functions, a connection is established with the LinkedIn servers. LinkedIn is informed that you have visited our Internet sites with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account, LinkedIn is able to assign your visit to our Internet site to you and your user account. We would point out that we as the provider of the sites do not know the content of the data that is transmitted or how LinkedIn uses this.
You can find more information on this in data privacy declaration of LinkedIn at:
We receive anonymous statistics on the use and utilization of the fan pages from Instagram due to the legitimate interest according to Article 6 Para. 1 f) GDPR. The following information is provided:
− follower: Number of people who follow us – including growth and development over a defined period of time,
− reach: Number of people who see a specific contribution. Number of interactions on a contribution,
− ad performance: How many people were reached with a contribution or a paid ad and have interacted with it?
We use these statistics, from which we cannot draw conclusions about individual users, to constantly improve our presence on Instagram and to better respond to the interests of our users. We cannot link the statistical data with the profile data of our fans. We receive personal data via Instagram if you actively communicate this to us via a personal message on Instagram. We use your data (e.g., first name, surname) to answer your request and in case of follow-up questions. The processing of personal data in this case serves us to process your contact and in case of follow-up questions. The legal basis for the processing of the data is our legitimate interest in answering your request in accordance with Article 6 Para. 1 f) GDPR and, if applicable, Article 6 Para. 1 b) GDPR, if your request is aimed at the conclusion of a contract. The data will be deleted by us as soon as they are no longer required for the purpose of their collection and no legal obligations to retain them exist, or when the respective conversation with the user has ended. The conversation is terminated when it can be concluded from the circumstances that the matter in question has been finally clarified.
Siekmann Econosto übermittelt Ihre personenbezogenen Daten gegebenenfalls an:
− other SE and group companies if this is necessary in the context of the offering and operation of the SE Online offerings or the initiation, implementation or handling of the business relationship,
− IT service providers who process data as part of their service provision (such as service providers for IT maintenance activities), or
courts, tribunals, authorities, or legal advisers when required to comply with applicable law, or to assert, exercise, or defend legal claims. Some of the recipients are based in countries whose data protection laws provide a level of protection that does not equal the level of protection in the country in which you are based. In this case Siekmann Econosto shall take steps to otherwise ensure appropriate and adequate safeguards to protect personal data.
− We will therefore only pass on your personal data to SE and group companies in such countries if they have implemented the (i) SE Data Protection Guidelines or the (ii) Binding Corporate Rules (BCR) of the group for the protection of personal data..
− Personal data will only be transferred to non-group recipients in such countries if they (i) have concluded EU standard contractual clauses with SE or (ii) have introduced Binding Corporate Rules or (iii) – in the case of recipients based in the USA- are certified under the EU/US Privacy Shield.
Further information is available at firstname.lastname@example.org.
Personal data published by you via SE Online offerings (for example, in chat rooms or forums) may be accessible to other registered users of the respective SE Online offerings worldwide.
If no explicit retention period is specified for the collection (e.g. as part of a declaration of consent), your personal data will be deleted if it are no longer required for the fulfilment of the purpose of the storage, unless statutory retention requirements (for example commercial and fiscal retention requirements) prevent deletion.
If you have given us consent to the processing of your personal data, you have the right to revoke your consent at any time with future effect. The revocation does not affect the legality of the processing carried out prior to the revocation on the basis of the consent. After revocation, Siekmann Econosto may further process the personal data only to the extent that SE is able to justify the processing on another legal basis.
Under applicable data protection law, you may have the right to:
− request confirmation as to whether Siekmann Econosto is processing personal data about you and to obtain information about the personal data processed by SE and other information
− request the correction of incorrect personal data
− request the deletion of personal data processed by SE
− request that SE restrict the processing of personal data
− request the transfer of the data or
− object to the processing of personal data by SE.
Dortmund, Mai 2018