Privacy Policy for HubSense Commissioning
Tool
Our business is based on trust. Inventronics
companies around the globe are committed to protecting personal data and
therefore we undertake to comply with the EU General Data Protection Regulation
(“GDPR”) and other
applicable data protection laws and strive to constantly improve our internal
data protection processes.
THIS PRIVACY POLICY IS DESIGNED SPECIFICALLY FOR
INFORMATION OF USERS OF THE HUBSENSE COMMISSIONING TOOL (ALSO THE “TOOL”) AND PROVIDES
YOU WITH A DETAILED OVERVIEW OF PERSONAL DATA THAT IS COLLECTED AND PROCESSED
BY INVENTRONICS IN THE HUBSENSE COMMISSIONING TOOL, PURPOSES OF RESPECTIVE
PROCESSING ACTIVITIES AND OUR PRIVACY PRACTICES.
PLEASE, READ THIS PRIVACY POLICY BEFORE USING THE
HUBSENSE COMMISSIONING TOOL, INCLUDING ITS WEB-BASED VERSION AND MOBILE
APPLICATION AS WELL AS OTHER ASSOCIATED SOFTWARE. YOU CAN ONLY ACCESS AND USE
THE TOOL, IF YOU AGREE TO AND ACCEPT THE PROVISIONS OF THIS PRIVACY POLICY AND
PROVIDE YOUR CONSENT TO DATA PROCESSING ACTIVITIES, AS SET OUT BELOW.
1.
Name and
contact details of the Controllers:
Data Controller
responsible for data processing in the HubSense
Commissioning Tool within the meaning of the EU General Data Protection
Regulation is:
INVENTRONICS GmbH
Parkring
31-33
85748 Garching
Germany
Phone: +49 89 6213-0
E-mail: webmaster@osram.com
Internet: http://www.inventronicsglobal.com
Our business partner Silvair sp. z o.o. (“Silvair”), which is a limited liability company incorporated
under the laws of Poland, with its registered office in Kraków at ul. Jasnogórska 44, 31-358
Kraków, Poland, manages the HubSense Commissioning
Tool and therefore is an independent Data Controller responsible for the
processing activities necessary to supply, operate and maintain, enhance and
improve the Tool, to assess and improve their business, and to carry out
anonymization of the collected data.
PLEASE READ ABOUT PERSONAL AND OTHER DATA PROCESSED
BY SILVAIR AND ITS USE AS WELL EMPLOYED PRIVACY SAFEGUARDS IN SILVAIR COMMISSIONING PRIVACY NOTICE BEFORE USING THE HUBSENSE COMMISSIONING TOOL.
2.
Scope of data
collection
The following
data is collected by Inventronics in the context of the HubSense
Commissioning Tool:
• name, email
address, phone number and other personal data provided to Inventronics by a
user of the Tool necessary for the provision of the technical support;
• names, contact
details and other personal data collected by Osram within the framework of
additional services, offered to users directly in lighting projects in the Tool
(e.g., the precommissioning service);
• other personal
data necessary for operation, maintenance and improvement of the HubSense Commissioning Tool.
3.
Legal basis
for data processing
The legal basis
for the processing of personal data in the context of the HubSense
Commissioning Tool is a consent of users to the processing of their personal
data (Art. 6 para. 1 point (a) GDPR).
4.
Purposes of
data processing
The data collected by Inventronics in the context
of the HubSense Commissioning Tool is used for the
following purposes:
• provide users of the Tool with technical support;
• provide additional services to users directly in
lighting projects;
• perform anonymization of the personal data
collected and stored;
• to protect against, identify and prevent fraud and
other criminal activity, claims and other
liabilities;
• to comply with applicable legal requirements
applicable to the Inventronics and its internal policies;
• analyze, enhance and improve the Tool (including developing new features
and services).
5.
Disclosure
and transfer of personal data
Inventronics
may share your personal data with:
• other Inventronics
group companies.
• in case of
involvement of required service providers to any such service provider
(including IT providers).
If external recipients of the data are located
within a Member State of the European Union (“EU”) or within a Member State of
the European Economic Area (“EEA”), Inventronics concludes order processing
agreements with them according to Art. 28 GDPR.
In case if recipients are in countries without
adequate level of data protection, INVENTRONICS has taken measures to ensure
appropriate and adequate guarantees for the protection of personal data. If the
data is transferred:
• to group companies in such countries, it will be
ensured that these companies have signed
and adhere to
the binding company policy for the safety of the personal data (Binding
Corporate Rules
“BCR”).
• to external recipients in such countries, the data
will only be transferred (i) if they have
signed the EU
standard contractual clauses with INVENTRONICS or (ii) - for recipients in the
USA - if they are certified under the EU/US Privacy Shield.
6.
Retention
periods
Personal data collected by Invenronics
in the context of the HubSense Commissioning Tool
will be deleted, (i) if it is no longer necessary for
the purposes of data processing indicated above and (ii) there are no legal
obligations to keep the data (e.g. trading, tax or pension retention
obligation).
7.
Withdrawal of
consent
You have the right to withdraw consent to the data
processing by Inventronics in the context of the HubSense
Commissioning Tool at any time with effect for the future. This means that any
processing based on your consent prior to the withdrawal will remain valid. In
this case, we may still be authorised to process your
personal data after withdrawal your consent, if we have the legal basis for
such processing, for the purposes determined by that legal basis.
Please, note that if you withdraw your consent for
one of the purposes indicated above, then, in some situations the
functionalities of the HubSense Commissioning Tool
may not be available for you.
8.
Your other
rights
If your
personal data is processed in the HubSense
Commissioning Tool, you are a data subject within the meaning of the GDPR and
you have the following rights vis-à-vis Inventronics:
• to access to your personal data by requesting
sharing and/or sending a copy of all your personal data processed by us;
• to request rectification of inaccurate personal
data by indicating the data requiring rectification;
• to request erasure of your personal data; we have
the right to refuse to erase the personal data in specific circumstances
provided by law;
• to request restriction of processing of your
personal data by indicating the data which
should be
restricted;
• to object to processing your personal data
conducted based on grounds relating to your particular situation.
Please contact Inventronics Data Privacy Office at privacy@inventronicsglobal.com , if you are willing to assume any of the above
rights.
Please, note that Inventronics has no possibility
to satisfy your legal rights regarding data processing in the context of the HubSense Commissioning Tool carried out by Silvair (see para. 1 above). In case you want to make use
of any of your data subject rights in relation to the data processed by Silvair, please contact Silvair
directly. You can find more information on how you can contact Silvair here.
Without prejudice to any other administrative or
judicial remedy, you have the right to lodge a complaint with a supervisory
authority in the EU-Member State of your habitual residence, your place of work
or place of the alleged infringement, if you believe that the processing of
personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint
has been lodged shall inform the complainant on the progress and the outcome of
the complaint including the possibility of a judicial remedy pursuant to Art.
78 GDPR.
9.
Updates to
this Privacy Policy
This Privacy
Policy may be amended from time to time. You can find the date when it was last
updated on the top of the given document.
10. Inventronics Data Privacy Office
The OSRAM Data Privacy Office is pleased to support
you with all inquiries regarding data protection – just contact us at privacy@inventronicsglobal.com .
f you want to know more about our data privacy
practices and commitments, please visit our Privacy
Policy on https://www.inventronics-light.com/privacy-policy