Data Privacy Notice

October 2019

Protecting the security and privacy of your personal data is important to CURRAX. Therefore, CURRAX (for further company details, please see the “Corporate Information” below) processes personal data in compliance with applicable laws on data protection and data security.

1. Processing of personal data related to your use of our websites, applications and online platforms 

Categories of personal data processed, purpose of the processing and legal basis 

When visiting CURRAX’ websites, applications or online tools (each a “CURRAX Online Offering”), CURRAX may process the following personal data about you:

• Personal data that you actively and voluntarily provide via the CURRAX Online Offering (e.g., when registering, contacting us with your inquiries or participating in surveys, etc.), including name, e-mail address, telephone number, information submitted as part of a support request, comments or forum posts, etc.; and
• Information that is automatically sent to us by your web browser or device, such as your IP-address, device type, browser type, referring site, sites accessed during your visit, the date and time of each visitor request.

We process your personal data for the following purposes: 

• To provide the CURRAX Online Offering’s services and functions and to administer your use of the CURRAX Online Offering;
• To verify your identity (if you registered for a CURRAX Online Offering);
• To answer and fulfill your specific requests;
• To send you marketing information or to contact you in the context of customer satisfaction surveys as further explained in Section 3; and
• As reasonably necessary to enforce the applicable terms of use, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on CURRAX’ information technology systems.

The legal basis for CURRAX processing data about you is that such processing is necessary for the purposes of:

• CURRAX exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation); 
• Compliance with CURRAX’ legal obligations (Article 6 (1) (c) General Data Protection Regulation); and/or
• Legitimate interests pursued by CURRAX (Article 6 (1) (f) General Data Protection Regulation). Generally the legitimate interest pursued by CURRAX in relation to our use of your personal data is the efficient performance or management of your use of the CURRAX Online Offerings.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for CURRAX processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

Cookies

We may use cookies within CURRAX Online Offerings. You can find information on CURRAX’ use of cookies in our Cookie Policy. The Cookie Policy also provides information on how to block and object to the use of cookies and the processing of data collected by cookies.

Links to other websites

This Privacy Notice applies only to CURRAX Online Offerings and not to other websites or applications operated by third parties. We may provide links to other websites and applications which we believe may be of interest to you. CURRAX is not responsible for the privacy practices of such other websites or applications.

2. Processing of personal data related to your business relationship with CURRAX

Categories of personal data processed, purpose of the processing and legal basis

In the context of the business relationship with CURRAX, CURRAX may process the following categories of personal data of consumers and contact persons at (prospective) customers, suppliers, vendors and partners (each a “Business Partner”): 

• Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address;
• Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
• Further information necessarily processed in a project or contractual relationship with CURRAX or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones;
• Personal data collected from publicly available resources, integrity data bases and credit agencies; and
• If legally required for Business Partner compliance screenings: date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners.

CURRAX may process the personal data for the following purposes:

• Communicating with Business Partners about products, services and projects of CURRAX or Business Partners, e.g. by responding to inquiries or requests or providing you with technical information about purchased products;
• Planning, performing and managing the (contractual) relationship with Business Partners; e.g. 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;
• Administrating and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests, or other promotional activities or events;
• Conducting customer satisfaction surveys and direct marketing activities as further explained in Section 3;
• 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 CURRAX policies or industry standards; and
• Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims.

The legal basis for CURRAX processing data about you is that such processing is necessary for the purposes of:

• CURRAX exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
• Compliance with CURRAX’ legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or
• Legitimate interests pursued by CURRAX (Article 6 (1) (f) General Data Protection Regulation).

Generally the legitimate interest pursued by CURRAX in relation to our use of your personal data is the efficient performance or management of our business relationship with you.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for CURRAX processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

3. Processing for personal data for customer satisfaction surveys and for direct marketing

Where and as permitted under applicable law, CURRAX may process your contact information for direct marketing purposes (e.g. trade show invitations, newsletters) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these  purposes at any time by writing to Datenschutz@currax.net  or by using the opt-out mechanism provided in the respective communication you received.

4. Transfer and disclosure of personal data

CURRAX may transfer your personal data to: 

• other CURRAX companies or third parties - e.g. sales partners or suppliers - in connection with your use of the CURRAX Online Offerings or our business relationship with you;
• third parties which provide IT services to CURRAX and which process such data only for the purpose of such services (e.g., hosting or IT maintenance and support services); and/or
• third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to law enforcement authorities and regulators, to attorneys and consultants).

Sometimes the recipients to whom CURRAX transfers your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country.

In such cases, CURRAX takes measures to implement appropriate and suitable safeguards for the protection of your personal data. In particular:

• We share your personal data with CURRAX companies in such countries only if they have implemented the Binding Corporate Rules („BCR“) for the protection of personal data. For more information and a copy of the measures implemented, please contact Datenschutz@currax.net.
• We transfer personal data to external recipients in such countries only if the recipient has (i) entered into EU Standard Contractual Clauses with CURRAX, (ii) implemented Binding Corporate Rules in its organization or (iii) – in case of US recipients – the recipient is certified under the Privacy Shield. You may request further information about the safeguards implemented in relation to specific transfers by contacting Datenschutz@currax.net.

Personal data published by you on CURRAX Online Offerings (such as chat rooms or forums) may be globally accessible to other registered user of the respective CURRAX Online Offering.

5. Retention periods

Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary (i) for the purposes for which they were collected or otherwise processed, or (ii) to comply with legal obligations (such as retention obligations under tax or commercial laws).

6. Withdrawal of consent

In case you declared your consent for the processing of certain personal data by CURRAX, you have the right to withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, CURRAX may only further process the personal data where there is another legal ground for the processing.

7. Your rights

Under applicable data protection law you may have the right to:

• Obtain from CURRAX confirmation as to whether or not personal data concerning you are being processed, and where that is the case, access to the personal data;
• Obtain from CURRAX the rectification of inaccurate personal data concerning you;
• Obtain from CURRAX the erasure of your personal data;
• Obtain from CURRAX restriction of processing regarding your personal data;
• Data portability concerning personal data, which you actively provided; and
• Object, on grounds relating to your particular situation, to processing of personal data concerning you.

Further background information and explanations related to the rights described above are available on the European Commissions’ website “Rights for citizens”.

7. Data privacy contact

The CURRAX Data Protection Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights.

The CURRAX Data Privacy Organization may be contacted at: Datenschutz@currax.net

The CURRAX Data Privacy Organization will always use best efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the CURRAX Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.

A list and contact details of local data protection authorities is available here.