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PRIVACY POLICY

Below, we explain which personal data we collect about you and how we use this data. We also inform you about your data protection rights and who you can contact with questions regarding the protection of your data.

About Us

Controller responsible for processing your data:

ET GLOBAL GmbH
Franklinstraße 61-63
60486 Frankfurt am Main
+49.69795882-0
Email: europe@etglobal.com

If you have any questions regarding this privacy policy, the processing of your data, your rights, or other data protection concerns, our Data Protection Officer will be happy to assist you.

Contact details of the Data Protection Officer:

Xamit Bewertungsgesellschaft mbH
Monschauer Straße 12
40549 Düsseldorf, info@xamit.de 

Scope

This privacy policy applies to the website ETglobal.com and is intended for visitors to our website.

Our website may contain links to external websites operated by other parties, to which this privacy policy does not apply.

Responsibility for advertisements, such as banners, text ads, or commercials shown before or during embedded videos, lies with the respective operator.

Do I have to provide my data?

When you visit our website, user data is automatically stored. Some of this data is necessary for the use of the website. Additionally, we process your data to protect our legitimate interests, following a balancing of interests. This enables us to continuously improve the services we offer.

You will find more details about our interests and how you can object to or deactivate the use of your data in the sections below.

To use certain services or submit inquiries, you may be asked to provide personal data. You can decide whether to use these services and provide your data. Some services are only provided if you give us your consent, which is always voluntary and can be revoked at any time.

If you provide information about other individuals, please ensure you have obtained their consent and informed them of the purposes of the data transfer as outlined in this privacy policy.

Please also share this information with individuals you involve in using our services, such as family members or authorized representatives.

Purposes of Processing, Legal Bases, and Processed Data

We distinguish between various types of data processing, which are described below.

Service Provision

To visit and use our website, certain data must be collected. We process this data to safeguard our legitimate interest in providing a functional website (Art. 6(1)(f) GDPR).

Data Security

Every access to our website is stored and analyzed in a log file. We process this data for the purpose of ensuring data security. This processing is carried out to protect our legitimate interest in maintaining data security (Art. 6(1)(f) GDPR).

Handling Inquiries

We process the data you provide when you submit a question or concern, including data sent via email. This processing is necessary to respond to your inquiry and is based on our legitimate interest in addressing your questions and concerns (Art. 6(1)(f) GDPR).

Handling Booking Requests

We process the data you provide when making a booking via our booking tool. This processing is necessary to manage your booking and is based on our legitimate interest in handling such requests (Art. 6(1)(f) GDPR).

Displaying Videos

To use the embedded videos on our website, the specified data must be processed. Your data will only be processed and shared with the service provider Google Ireland Ltd (“Google”) once you have given your consent by activating the video service (Art. 6(1)(a) GDPR). This allows Google to recognize that our website was accessed via your IP address. Google may also use this data for analyzing user behavior and for market research and marketing purposes. For more information on how Google handles user data, please refer to Google’s privacy policy.

Newsletter

You can subscribe to our newsletter, for which we require the specified data. The newsletter is sent based on your consent (Art. 6(1)(a) GDPR). Additionally, we process your data to select suitable recipients for our offers, which is based on our legitimate interest in targeted distribution (Art. 6(1)(f) GDPR).

Optimization and Billing of Advertisting Measures Inluding Profiling

To optimize and bill advertising measures and enable retargeting of website visitors, marketing cookies are set (subject to your consent). This assigns you a unique user ID to identify repeat visits. We use your data to utilize marketing services and products, including SEO, content creation, and email marketing. This allows us to evaluate the effectiveness of our advertising and bill our advertising partners. Your visit data is not linked to your name or other personal information (if provided).
Processing is based on your consent (Art. 6(1)(a) GDPR). You can find information on how to revoke your consent in the “Information about Cookies” section.

Optimization of the Website Including Profiling

We continuously improve our website to offer optimal user experience. For this purpose, statistical cookies are set (subject to your consent), and data about your website usage is collected. A unique user ID is assigned to identify repeat visits. We use your data to analyze usability, functionality, and attractiveness of our website and user behavior. Your data is aggregated into non-personal statistics. This enables us to fix errors, improve navigation, and develop our website and marketing activities. Your visit data is not linked to your name or other personal information (if provided).

Processing is based on your consent (Art. 6(1)(a) GDPR). You can find information on how to revoke your consent in the “Information about Cookies” section.

Informationen about Cookies

If we use cookies that are necessary for the operation of the website, the processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in providing a functional website.

All cookies used for optimizing the website (including profiling) or for optimizing and billing advertising measures (including profiling) are only set if you have given us your consent (Art. 6(1)(a) GDPR).

When you view embedded YouTube videos on our website, cookies are set by Google Ireland Ltd (“Google”), which may also use the data for analyzing user behavior and for market research and marketing purposes. These cookies are only set if you consent to the processing. You can delete cookies at any time via your browser settings.

A detailed list of cookies, including their names, functions/purposes, and retention periods, can be found in our Cookie Manager.
You may withdraw your consent at any time without providing reasons.

Processed Data

The following table outlines which types of data are processed for each respective purpose:

Data

Service Provision

Data Security

Optimization and Billing of Advertising Measures incl. Profiling

Optimization of Website incl. Profiling

Handling Inquiries

Handling Booking Requests

Video Display

IP address

x x x x     x

Name of accessed file

  x x x     x

Transferred data volume

  x x x     x

Accessed website

x   x x     x

Referrer-URL (previously visited page)

  x x x     x

Search terms (keywords and their IDs)

    x x     x

User agent sent by your browser

x x x x     x

Session cookie

  x x x     x

Google cookies

    x x     x

Datum and time of access

  x x x     x

Date and time of last user activity (for session timeout)

    x x     x

IDs for identifying advertising partner, ad, and advertisinf medium

    x       x

Marketing channel

    x x     x

Current time

x x x x     x

Time of click

    x x     x

Visitor ID (non-personal)

    x x     x

Operating system

    x x     x

Browser information (type, version, resolution, language)

x   x x     x

Screen format, resolution incl. color depth

      x     x

URL of viewed page/downloads

    x x     x

Cookie enabled/disabled

x            

JavaScript enabled/disabled

x   x x     x

Mouse movement within browser window

      x     x

Statistical cookies

      x      

Marketing cookies

    x        

Salutation, name

        x x  

Contact details (email, address, phone, fax)

        x x  

Subject, topic, concern

        x x  

Message content

        x x  

Time of message receipt/registration

        x x  

Sent campaign

    x        

 

Other Purposes of Processing

In addition to the purposes mentioned above, the data listed may also be processed based on a balancing of interests (Art. 6(1)(f) GDPR). The legitimate interests are described below:

  1. In the event of a security incident within our company that affects your data, we are legally obligated to report the incident to the competent data protection supervisory authority (Art. 33 GDPR). As it is in our legitimate interest to comply with this legal reporting obligation as quickly as possible, your personal data may be processed during the investigation of the incident. These reports do not contain any of your personal data.
  2. To ensure the security of our systems, we regularly conduct security and effectiveness tests, during which your data may be processed.
  3. In the event of legal disputes, we process your data for the purpose of resolving such disputes. It is also in our legitimate interest to retain evidence until all relevant statutory limitation periods under Sections 195 et seq. of the German Civil Code (BGB) have expired. Accordingly, we retain the relevant data for the duration of these limitation periods. These periods can vary depending on the nature of the dispute and may be up to 30 years. The regular limitation period is 3 years.
  4. Furthermore, it is in our legitimate interest to investigate suspected cases and, in the event of concrete suspicion of a criminal offense, to forward relevant information to law enforcement authorities.
  5. We conduct audits, internal reviews, and other control measures (e.g., monitoring by the Data Protection Officer) to comply with legal requirements, ensure transparency in our business processes, continuously optimize these processes, and prevent or detect harmful actions. In doing so, documents or files containing your personal data may be processed.
  6. Errors can occur in any business process or system. To optimize these processes and systems and reduce our error rate, we process the data available within our company to identify sources of error. This process is carried out to protect our legitimate interest in improving our processes and systems.
  7. We process your data for testing IT systems and software products, as well as for conducting data migrations. This process is carried out to fulfill our legitimate interest in verifying the accuracy of new products and the correctness and completeness of migrations.

Retention Periods (or Storage Duration)

Data processed for the purpose of data security is deleted after 30 days. (Note: These refer to log files. Depending on the hosting provider or IT system, a retention period of 3 to 7 days may be more appropriate. HubSpot stores this data for 30 days.)

Data used for the optimization and billing of advertising measures including profiling is deleted after 180 days. (Note: This refers to raw personal data. Aggregated, non-personal data does not need to be deleted.)

Data used for the optimization of our website including profiling is deleted after a maximum of 14 months. (Note: This refers to raw personal data. Aggregated, non-personal data does not need to be deleted.)

Data processed for the purpose of contact via the contact form is deleted after the inquiry has been fully handled, provided no retention obligation applies due to a resulting contractual relationship. (Note: If no contract is concluded, data may be stored for up to 3 months. If a contract is concluded, a retention period of 6 years applies.)

To preserve evidence, we retain data in accordance with the statutory limitation periods under Sections 195 et seq. of the German Civil Code (BGB). As a result, the storage duration of your data may exceed the periods mentioned above.

The statutory periods can be up to 30 years, with the regular limitation period being 3 years.

Origin of Data

No data is collected from third parties.

Information on Automated Individual Decision-Making

No automated individual decision-making takes place.

Who Receives Your Data?

The following list shows which entities may receive your data (“data recipients”). You can find details about the specific data involved in the relevant sections of this privacy policy.

In some cases, data is shared due to legal or contractual obligations. In other cases, we use selected agents and service providers who act as processors (in accordance with Art. 28 GDPR) and may access your data to the extent necessary.

Processors are subject to strict contractual obligations and may only process your personal data on our instructions and solely for the purposes assigned to them.

Data recipients may include:

  • Auditors
  • Data Protection Officer
  • Video display service providers
  • Data carrier destruction service providers
  • Newsletter distribution service providers
  • Website optimization service providers
  • Advertising billing and optimization service providers
  • Email providers of the recipient (in case of email communication)
  • IT service providers
  • Lawyers, law enforcement authorities, public prosecutors, courts, opposing counsel, authorities (in case of legal disputes or criminal suspicion)
  • Social networks, professional networks
  • Telecommunications providers (in case of phone communication)
  • Postal service providers (in case of written communication)

Data Recipients in Non-EU Countries

Our IT service providers and video display service providers located in the EU may have affiliated companies or subcontractors outside the EU who can access your data.

The European Commission determines which non-EU/EEA countries (“third countries”) offer an adequate level of data protection.

Affiliated companies or subcontractors of our IT service providers are either certified under the EU-U.S. Data Privacy Framework (Commission Decision No. C(2023) 4745 final of July 10, 2023), if based in the U.S., or our IT service providers are responsible for applying EU Standard Contractual Clauses in accordance with Commission Decision No. (EU) 2021/914.

A sample of these EU Standard Contractual Clauses can be found on the websites of the EU Commissioner for Justice and in the Official Journal of the EU.
You have the legal right to:

  • Access your stored personal data (Art. 15 GDPR)
  • Rectification and completion of your data (Art. 16 GDPR)
  • Erasure of your data (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Withdrawal of consent (Art. 7 GDPR) with future effect. The lawfulness of processing prior to withdrawal remains unaffected.
  • You also have the right to express your point of view and contest decisions based solely on automated processing (Art. 22 GDPR).
  • You have the right to object to the processing of your data based on our legitimate interests or those of third parties (Art. 21 GDPR). You may object at any time for reasons arising from your particular situation. This also applies to profiling based on these provisions (Art. 4(4) GDPR).
  • Objection to Direct Marketing – You have the right to object at any time, without providing reasons, to the processing of your data for direct marketing purposes.

To exercise these rights, you may contact us using the contact details provided above.

You also have the legal right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).