EURELEC Privacy Policy for Customers, Suppliers and Partners

Last updated: 04 September 2024

1. About this Policy

1.1 This Privacy Policy (the “Policy”) describes how we collect, share and use all information which, taken alone or in combination with other information, relates to you (“Personal data”) as a customer, supplier or partner (or as our contact person for these entities) (“you” and “your”) of EURELEC Trading SC ("EURELEC", “we” or “our”).

1.2 This Policy also sets out your rights in relation to the Personal data about you that we process, and explains how you can exercise them.

1.3 EURELEC takes its responsibilities as regards data protection very seriously. That is why we have developed this Policy setting out the standards to which we operate in order to protect your Personal data.

1.4 For the purposes of this Policy, EURELEC, with whom you have entered into an agreement, acts as controller for your Personal data. In its capacity as controller, EURELEC is responsible for ensuring that Personal data is processed in accordance with current data protection legislation, and in particular the General Data Protection Regulation (“GDPR”).

1.5 Please take the time to read this Policy carefully. If you have any questions or comments, please contact us by emailing privacy@eurelec-trading.eu .

2. What Personal data we collect and why

2.1 The types of Personal data that we collect, and the reasons why we process it include:

If we ask you to provide Personal data other than that described above, we will let you know which data we are asking you to provide and why as and when it is required.

2.2 From time to time, we may receive Personal data relating to you from third parties, for example through commercial events, industry seminars, etc., but only if we have checked that these third parties are legally permitted or obliged to communicate your Personal data to us.
The categories of Personal data that we collect from third parties include contact details, company, type of business, etc. and we use this Personal data that we receive from third parties to maintain and improve the accuracy of the data that we hold about you.

2.3 As a general rule, we only use the Personal data that we collect from you for the purposes set out in this Policy or for those purposes that we explain to you as and when required. However, we may also use your Personal data for other purposes that are not incompatible with the purposes that we have communicated to you (such as processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes), on the condition that they are authorised by the applicable data protection legislation.

3. Who we share your data with

3.1 We may communicate your Personal data to the following categories of recipients:

(a) companies in our group for purposes in accordance with this Policy. We take precautions to ensure that access to Personal data is limited to staff members with a legitimate business need.

(b) our third-party suppliers, service providers and partners who provide us with data processing services or who process the Personal data for the purposes set out in this Policy or of whom we make you aware when we collect the Personal data. This can include communicating the Personal data to third parties and to other service providers whose services we use, in particular to support us in areas such as IT platform management or support services, infrastructure and application services, marketing, data analysis and business travel services,

(c) any relevant law enforcement agency, regulator, government agency, court or other third party when we judge that it is necessary for us to divulge the information (i) in accordance with applicable laws or regulations, (ii) to assert or defend our rights, or (iii) to protect our vital interests or those of any other person,

(d) our auditors, advisers, legal representatives and similar agents within the context of the consultancy services that they supply to us for legitimate commercial purposes and under a contractual prohibition to use the Personal data for other purposes,

(e) a potential buyer (and their agents and advisers) within the context of a planned purchase, merger or acquisition of a part of our business, on the condition that we inform the buyer that they must not use the Personal data for any purposes other than those laid down in this Policy,

(f) any other person when you have given your prior consent for your Personal data to be divulged.

4. How we protect your privacy

4.1 In accordance with this Policy, when we process your Personal data we apply the following principles:

(a) Honesty: we will process your Personal data in an honest manner. This means that we will be transparent about how we process your Personal data, and that all the processing we carry out will be within the confines of the applicable laws.

(b) Limitations on purposes: we will process the Personal data for determined, lawful purposes and we will not process it in any way that is not compatible with these purposes.

(c) Proportionality: we will process the Personal data in a manner proportional to the purposes which the processing is intended to achieve.

(d) Accuracy of data: we will take appropriate measures to ensure that the Personal data that we hold is accurate, comprehensive and, where necessary, kept up to date. Nevertheless, you are also responsible for ensuring that your Personal data is as accurate, comprehensive and up to date as possible by informing Us of any modification or error. You must inform your local contact of any change to the Personal data that we hold about you (for example, a change of address).

(e) Data security: we use the appropriate technical and organisational measures to protect the Personal data about you that we collect and process. The measures that we use are designed to offer a level of security commensurate with the risks of processing your Personal data.

(f) Sub-contracting: we may subcontract the processing of Personal data for and on behalf of EURELEC to third parties.. We require these third parties to process the Personal data and operate strictly according to our instructions and to take the appropriate measures to ensure that the Personal data remains protected.

(g) International data transfers: your Personal data may be transferred to and processed in countries other than your country of residence. The data protection laws in place in these countries may differ from those in place in your own country.

More precisely, our servers are located within the EEA, whereas our group companies and our service providers and third party partners operate all over the world. This means that when we collect your Personal data, we may process it in all these countries.

However, we have taken appropriate protection measures to require that your Personal data continues to be protected in accordance with this Policy. This includes putting in place an intragroup framework data transfer agreement based on the European Commission’s standard contract clauses for the transfer of Personal data between companies in our group, requiring that all group companies protect the Personal data originating from the EEA that they process in accordance with European Union data protection laws (the “Intragroup Framework Data Transfer Agreement”).

Our Intragroup Framework Data Transfer Agreement (or extracts from it) can be provided on request. We have put in place similar appropriate safeguards with our third-party service providers and partners and further details can be supplied on request.

(h) Data retention: we keep the Personal data that we collect from you when we have a legitimate business need to do so (for example, to supply a service that you have requested or to comply with relevant legal, tax or accounting requirements).

When we do not have any legitimate business need to process your Personal data, we will delete or anonymise it, or if this is impossible (because, for example, your Personal data has been stored in a backup archive), we will store it securely and isolate it from any further processing until it can be deleted.

5. Your data protection rights

5.1 You have the following data protection rights:

(a) If you wish to access, correct or update your Personal data, or ask us to delete it, you can do so at any time by contacting privacy@eurelec-trading.eu.

(b) IIf your Personal data is being processed on the basis of our legitimate interest, you have the right to object to the processing of your Personal data (you can find out when your Personal data is processed on the basis of our legitimate interest in clause 2.1 of this Policy). In this situation, we will weigh up your right to privacy against our legitimate interests. If your right to privacy prevails over our legitimate interests, we will cease the relevant processing of your Personal data. You can exercise these rights by contacting privacy@eurelec-trading.eu .

(c) You have the right to ask us to limit the processing of your Personal data when you have contested the accuracy of the Personal data, for a sufficient period of time for us to check the accuracy of your Personal data; when our processing of your Personal data is unlawful but you object to your data being deleted and require us to limit our use of it instead; when we no longer require the Personal data for the original purpose, but it is still needed to contest, exercise or defend rights in a legal case; and when you have objected to the processing of your Personal data and while interests are being weighed up as set out above in clause 5.1 (a). You can exercise these rights by contacting privacy@eurelec-trading.eu

(d) You have the right to request data portability for your Personal data, which means the right to receive the Personal data that you have supplied to us in a structured, commonly used and machine-readable format, and to transfer this Personal data to another controller when the processing is based on your consent, or is necessary for the contract and automated processes are used in the processing. You can exercise these rights by contacting privacy@eurelec-trading.eu. If we have collected and processed your Personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the legitimacy of any processing that we carried out before it was withdrawn and will not affect Personal data processing carried out on the basis of lawful processing other than consent.

(e) You have the right to refuse the advertising communications that we send to you at any time. You can exercise this right by clicking the “unsubscribe” link in the advertising emails that we send you. To unsubscribe from other forms of advertising (such as direct postal mailing and digital advertising), please contact us at the address above.

(f) If you are concerned about the way we have processed your Personal data or wish to make a complaint, we will do our best to address your issue. If you feel that we have not taken sufficient account of your complaint or concern, you have the right to lodge a complaint with a data protection authority regarding our collection and use of your Personal data. For more information, please contact your local data protection authority. (Contact details for the data protection authorities in the EEA, Switzerland and certain other countries (including the United States of America and Canada) are available here.)

5.2 We reply to all requests that we receive from people wishing to exercise their rights in relation to the protection of their Personal data in accordance with the applicable data protection laws.

6. Updates to this Policy

6.1 We may update this Policy from time to time to take account of legal, technical and business developments. When we update our Policy, we will take the necessary measures to inform you, as appropriate to the significance of the changes made. We will obtain your consent for all major changes to this Policy, if the applicable data protection laws require us to do so.

6.2 The date on which this Policy was last updated is shown at the top of the document.
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