Privacy policy

Purpose of the processing and legal basis

The personal data are processed for communicating with Business Partners about products, services and projects;  planning, performing and managing the (contractual) relationship with business partners; administrating and performing customer surveys, marketing campaigns, market analysis, 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 solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims.

The legal basis for processing data about you is that such processing is necessary for exercising our rights and performing its obligations in connection with any contract (Article 6 (1) (b) GDPR); for compliance with OASE’s legal obligations (Article 6 (1) (c) GDPR), and/or for legitimate interests pursued by OASE (Article 6 (1) (f) GDPR).  The legitimate interest of OASE lies in the initiation, execution and management of the business relationship. When you have consented to the relevant use of your personal data, your consent is the legal basis for OASE processing that data about you (Article 6 (1) (a) GDPR).

 

Data storage and deletion

Your personal data will be retained by us only as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from the DPO.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

Your data protection rights:

 

The GDPR gives you a full range of rights concerning the data you provided.

 

Right of access : Acc. to Art. 15 GDPR you shall have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:

a.     the purposes of the processing;

b.     the categories of personal data concerned;

c.     the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d.     where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e.     the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

f.      the right to lodge a complaint with a supervisory authority;

g.     where the personal data are not collected from the data subject, any available information as to their source;

h.     the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

 

Right to rectification:  Art. 16 GDPR grants you the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure: Acc. to Art. 17 GDPR you shall have the right to obtain from us the erasure of personal data concerning you without undue delay and we shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a.     the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b.     you withdraw your consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;

c.     you object to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2);

d.     the personal data have been unlawfully processed;

e.     the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

f.      the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

Where we have made the personal data public and are obliged pursuant to paragraph 1 to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right of erasure shall not apply to the extent that processing is necessary:

a.     for exercising the right of freedom of expression and information;

b.     for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c.     for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);

d.     for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e.     for the establishment, exercise or defence of legal claims.

Right to restriction of processing: Acc. to Art. 18 GDPR you shall have the right to obtain from us restriction of processing where one of the following applies:

a.     the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b.     the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c.     we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

d.     you have objected to processing pursuant to Article 21(1) pending the verification whether our legitimate grounds those of yours.

Where processing has been restricted , such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing shall be informed by us before the restriction of processing is lifted.

Right to data portability: Acc. to Art. 20 GDPR you shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

a.     the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and

b.     the processing is carried out by automated means.

In exercising your right to data portability pursuant, you shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The exercise of this right shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

This right shall not adversely affect the rights and freedoms of others.

Right to object: Acc. to Art. 21 GDPR you shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

At the latest at the time of the first communication with you, the right referred to in both the above paragraphs shall be explicitly brought to your attention and shall be presented clearly and separately from any other information.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), you, on grounds relating to your particular situation, shall have the right to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.