Privacy Policy

2e Systems and its affiliated companies (“2e Systems Group”) are firmly committed to respecting and protecting the privacy of all personal data received or collected, in strict adherence to the relevant Data Protection Legislation and best business practices. The 2e Systems Group has established this Policy so that you can understand the care and effort with which we intend to treat personal data, as a standard.

Introduction
2e Systems’s data protection and privacy measures are governed by the

(i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time
and
(ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation”)
(iii) ePrivacy Directive (2002/58/EC and 2009/136/EC)

For the purpose of Data Protection Legislation:
1. where personal data is provided directly to 2e Systems through use of the Website, email, or other means where 2e Systems is determining the way in which that personal data is processed for its own use, then 2e Systems will be a data controller of such information;
2. where 2e Systems is provided personal data in its capacity of providing Services to its clients, then 2e Systems will only process that personal data in accordance with the instructions of its clients and 2e Systems will, therefore, act as a data processor in respect of such personal data; 2e Systems’s client will be the data controller of that personal data for that purpose and will be responsible to data subjects for the way in which their personal data is processed as the data controller.

Where 2e Systems acts as a data processor on behalf of its clients, 2e Systems will process that personal data on the instructions of its clients, who would have collected that personal data in accordance with that client’s own privacy policy. Individuals who have contracts with our clients should, therefore, check that client’s own privacy policy, to ensure they understand how their personal data may be processed.

Personal Data and Basis for Collection
Personal data means any data or information about an individual from which that person can be uniquely identified. Anonymized data where measures have been taken to make it impossible for a person to be uniquely identified is not considered personal data.

Where 2e Systems is acting as a data controller, 2e Systems may collect, use, store and transfer different kinds of personal data such as Authenticating, Identifying, Demographic, Contact, Location, Device, Preference data.

Additionally, we may collect and store information about how you use 2e Systems Services or submit an enquiry or query through the Website, as well as preferences and interests including information about 2e Systems’s Services that you might wish to hear about.

2e Systems will only use your personal data when the law allows us to, ie, if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Personal information
We may collect personal information from Users in a variety of ways, including, but not limited to, when Users visit our site, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name and email address. We will collect personal information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identifiable information, except that it may prevent them from engaging in certain Site related activities.

Your Rights
● The right to be informed – this is information on for what purpose we are processing it and what personal data we are processing.
● The right of access – you have the right to be provided with copies of the personal data of you that we are processing as well as confirmation of the processing we are doing. You can do this by sending a “subject access request” to the contact details noted above for our consideration.
● The right to rectification – if you think the personal data that we hold on you is wrong you can tell us and we will fix it.
● The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold for you then you can ask us to do so.
● The right to restrict processing – if you do not like how we are using your personal data then you can let us know and we will stop processing it in that way.
● The right to data portability – if you want us to pass on your personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your personal data.
● The right to withdraw your consent – you can withdraw your consent for us to process your personal data (if we have relied on your consent to process your personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your personal data then we will stop processing your personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your personal data aside from consent then we may do so even if you have withdrawn your consent.
● Rights in relation to automated decision making and profiling – if we use either automated decision making or profiling then you have a right to know. Also, we need your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

To exercise any of the above rights please email your request to our Data Protection Officer at privacy@2e-systems.com.

Non-personal information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies
Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

See our full Cookie Declaration

How we use collected information
2e Systems Group may collect and use Users personal information for the following purposes:
● To personalize user experience
● We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site
● To send periodic emails
● We may use the email address to respond to their inquiries, questions, and/or other requests.
● If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.

How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures.

Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

Changes to this privacy policy
2e Systems GmbH has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications. Where changes are significant, we may also email all our registered users with the new details, and where required by law, we will obtain your consent to these changes.

Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

2e Systems GmbH
Koenigsteiner Strasse 87
65812 Bad Soden am Taunus Germany

+49 6196 95058 0
info@2e-systems.com
www.2e-systems.com

Data Protection Officer:
Miroslav Schlossberg
privacy@2e-systems.com

This document was last updated on May 24, 2018