The subject matter of this agreement exclusively comprises the parties' declareations in German on our site of “Datenschutzerklärung”, not the English translation.
Diligence and transparency are the basis for a trusting cooperation with our customers. We inform therefore you about how we process your data and how you can exercise the rights entitled to under the General Data Protection Regulation (GDPR). Which personal data we process and for what purpose depends on the respective contractual relationship.
1. Who is responsible for data processing?
ELMO Europe SAS
Management: Mr. Masahito Inahara
1 Place des Degres
Tel.: +33 (0)6 21 48 02 50
2. Which of your personal data do we use?
If you have an inquiry, let us create an offer or conclude a contract with us, we will process your personal data. In addition, we process your personal data, among other things, to fulfill legal obligations, to protect a legitimate interest or based on your consent.
Depending on the legal basis, the following categories of personal data are involved:
- First name Last Name
- Communication data (telephone, e-mail address)
- Contract master data, in particular contract number, term, period of notice, type of contract
- Invoice data/sales data
- Credit Data
- Payment Data/Account Information
- Account information, particularly registration and logins
- Video or image capture
At the contract initiation, we also use data that third parties have made available to us, depending on the type of contract, the following categories of personal data are involved:
- Credit information (via credit bureaus)
3. What are the sources of the data?
We process personal data that we receive from our customers, service providers and suppliers.
We also receive personal data from the following places:
- Credit Bureaus
- Publicly accessible sources: commercial or association registers, lists of debtors, land registers
- Other group companies
4. For what purposes do we process your data and on what legal basis?
We process your personal data in particular in compliance with the General Data Protection Regulation (GDPR) and all other relevant laws.
4.1 Based on your consent (Art. 6 Paragraph 1a GDPR)
If you have given us your voluntary consent to the collection, processing or transmission of certain personal data, then this consent forms the legal basis for the processing of this data.
In the following cases we process your personal data based on your consent:
- Sending out an email newsletter
- Personalized newsletter tracking
- Market research (e.g., customer satisfaction surveys)
- Marketing and advertising-creation of customer profiles
- Publication of a customer reference (name and picture)
4.2 To fulfill a contract (Art. 6 Paragraph 1b GDPR)
We use your personal data to carry out the order /purchase agreement. Within this contractual relationship, we will process your data to carry out the following activities:
- Contract-related contact
- Contract management
- ongoing customer support
- Service center
- Assertion of warranty claims
- Claims management
- Contract termination management
Further information on the purposes of data processing can be found in the respective contract documents and general terms and conditions.
4.3 To fulfill legal obligations (Art. 6 Paragraph 1c GDPR)
As a company, we are subject to various legal obligations. Processing of personal data may be necessary to fulfill these obligations.
- Control and reporting obligations
- Credit, age and identity checks
- Prevention/defense of criminal acts
4.4 Based on a legitimate interest (Art. 6 Paragraph 1f GDPR)
In certain cases, we process your data to protect a legitimate interest of ours or a third party.
- Direct mail or market and opinion research
- Central customer data management in the group of companies
- Measures for building and system security
- Consultation and data exchange with credit agencies to determine creditworthiness and default risks
- Ensuring IT security and IT operations
5. Who is your data shared with?
In order to fulfill our contractual and legal obligations, your personal data will be disclosed to various public or internal bodies as well as external service providers.
- You can find TECHNO HORIZON Group companies at the following link: https://www.technohorizon.co.jp/company/group/oversea/
External service provider:
We work with selected external service providers to fulfill our contractual and legal obligations:
- IT service providers (e.g. maintenance service providers, hosting service providers)
- Service provider for document and data destruction
- Printing Services
- Payment Service Provider
- Advice and consulting
- Service providers for marketing or sales
- Credit Bureaus
- Service provider for telephone support (call center)
- Web hosting service provider
- Letter shops
- Storage and logistics service providers
In addition, we may be obliged to transmit your personal data to other recipients, such as to authorities to fulfill legal reporting obligations.
- Financial Authorities
- Customs authorities
6. Will your data be transmitted to countries outside the European Union (so-called third countries)?
Countries outside the European Union (and the European Economic Area (“EEA”) handle the protection of personal data differently than countries within the European Union. We also use service providers located in third countries outside the European Union to process your data. There is currently no decision by the EU Commission that these third countries generally offer an adequate level of protection.
We have therefore taken special measures to ensure that your data is processed just as securely in the third countries as it is within the European Union. With group members and service providers in third countries, we conclude the standard data protection clauses provided by the Commission of the European Union. These clauses provide suitable guarantees for the protection of your data with service providers in third countries.
7. How long will my data be stored?
We store your personal data for as long as it is necessary to fulfill our legal and contractual obligations.
8. What rights do you have in connection with the processing of your data?
Every data subject has the right to information under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR, the right to object from Art. 21 GDPR and the right to data portability from Art. 20 GDPR. The restrictions under §§ 34 and 35 BDSG apply to the right to information and the right to erasure.
8.1 Right to object
You can object to the use of your data for advertising using electronic mail at any time without incurring any costs other than the transmission costs according to the basic tariffs.
What are your rights in the case of data processing based on your legitimate or public interest?
In accordance with Article 21 Paragraph 1 GDPR, you have the right at any time, for reasons arising from your particular situation, to object to the processing of personal data relating to you, which is based on Article 6 Paragraph 1 e GDPR (data processing in the public interest ) or based on Art. 6 Paragraph1 f GDPR (data processing to protect a legitimate interest), to object; this also applies to profiling based on this provision.
In the event of your objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
What rights do you have in the case of data processing for the purpose of direct advertising?
If we process your personal data in order to operate direct advertising, you have the right pursuant to Art. 21 (2) GDPR to object at any time to the processing of your personal data for the purpose of such advertising, this also applies to profiling, to the extent that it is related to such direct mail.
If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.
8.2 Withdrawal of consent
You can revoke your consent to the processing of personal data at any time. Please note that the revocation only applies to the future.
8.3 Right to information
You can request information as to whether we have stored personal data about you. If you wish, we will tell you what data is involved, for what purposes the data is processed, to whom this data is disclosed, how long the data is stored and what other rights you have in relation to this data.
8.4 Other rights
In addition, you have the right to have incorrect data corrected or your data deleted. If there is no reason for further storage, we will delete your data, otherwise restrict processing. You can also request that we provide any personal data that you have provided to us in a structured, commonly used and machine-readable format, either to you or to a person or company of your choice.
In addition, there is a right of appeal to the competent data protection supervisory authority (Art. 77 GDPR in conjunction with Section 19 BDSG).
8.5 Exercising your rights
9. Is there an obligation to provide your personal data?
In order to enter into a business relationship, you must provide us with the personal data that is required to carry out the contractual relationship or that we must collect due to legal requirements. If you do not provide us with this data, it is not possible for us to carry out and process the contractual relationship.
10. Changes to this information
Should the purpose or manner of processing your personal data change significantly, we will update this information in a timely manner and inform you of the changes in a timely manner.