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PHONE HOTLINE: +49 69 795 8822 7003E-MAIL: europe@etglobal.com
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PHONE HOTLINE: +49 69 795 8822 7003E-MAIL: europe@etglobal.com
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de
Get in touch

PRIVACY POLICY WHATSAPP

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Privacy Policy for Communication via WhatsApp Business and Processing of Data in the USA

If you would like to communicate with us via WhatsApp Business, please note the following information on the functionality, encryption, risks of WhatsApp, use of metadata within the Facebook group of companies and your objection options. The use of WhatsApp is completely voluntary. Alternatively, you can contact us via the contact details provided to you or the contact details provided on our website (e.g. by post, telephone or e-mail).

Data Processing Outside the European Union

Our IT service providers in the EU have affiliates or subcontractors outside the EU who can access your data. The EU Commission determines which non-EU/EEA countries (third countries) have an adequate level of data protection. The affiliated companies or subcontractors of our IT service providers have either submitted to the so-called Data Privacy Framework (Resolution No. C(2923) 4745 final of 10.07.2023), provided that they are based in the USA; otherwise, our IT service providers will be responsible for the use of 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.

Legal Basis for the Processed Data

We use WhatsApp Business to be able to communicate easily with our customers, suppliers and the users of our services/products. The communication is intended to ensure faster and easier coordination between the parties and is used in addition to the usual means of communication. The use of the messenger service is based on your consent in accordance with Art. 6 (1) (a) GDPR.

In the case of responding to or processing your request in terms of content, processing is based on our legitimate interests in responding to your questions and concerns (Art. 6 (1) (f) GDPR). 

Further information on the purposes, types, and scope of the processing of your data by WhatsApp, as well as your rights and settings options for protecting your privacy, can be found in WhatsApp's privacy policy: https://www.whatsapp.com/legal/

You can object to communicating with us via WhatsApp at any time. If you subscribe to messages (also known as “broadcasts”) or status messages via WhatsApp, you can delete our corresponding phone number from your contacts and request that we remove your contact from our directory. In the case of ongoing individual inquiries or communications, you can also request that we do not continue communicating via WhatsApp. In the case of communication via WhatsApp, we delete the WhatsApp messages as soon as we can assume that we have answered any questions from users, if no reference to a previous conversation is to be expected and if there are no legal retention obligations that prevent deletion. Deletion from the systems we use takes place within 90 days. Furthermore, we would like to point out that we will not transfer the contact details provided to us to WhatsApp without your consent (e.g., by contacting you via WhatsApp).

We would like to point out that, for your security, we reserve the right not to respond to inquiries via WhatsApp. This is the case, for example, if the content of the communication requires special confidentiality or if a response via Messenger does not meet formal requirements. In such cases, we will refer you to more appropriate channels of communication.

Please note that if you provide information about other persons, you must have obtained their consent in advance and informed them of the purposes of the disclosure, as set out in this privacy policy.

We also ask you to pass on this information to the persons you involve in the use of our services, such as family members or authorized representatives.

Responsible Body

The responsible body pursuant to Art. 4 (7) of the GDPR for the collection, processing, storage, and use of personal data in connection with the described process is the

ET GLOBAL GmbH
Franklinstr. 61- 63
60486 Frankfurt am Main
+49 69 795 8822 7003 
europe@etglobal.com

Representatives of the responsible body: Dr. Magnus Ekerot

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

Data Protection Officer
ET GLOBAL GmbH
Franklinstr. 61- 63
60486 Frankfurt am Main
privacy@etglobal.com

Type of Data

As part of the WhatsApp service, we process the following personal data for the purpose of processing inquiries:

  • Phone number

  • WhatsApp name

  • Contents of WhatsApp messages received and sent

  • Date and time of WhatsApp messages received and sent

  • Profile picture

When using WhatsApp Business, different types of data are processed depending on your request. These may include the following data categories:

  • Master data (last name, first name, address)

  • Contact details (email address, phone number)

  • Content data (text entries, photographs, videos)

  • Date and time of WhatsApp messages received and sent

Furthermore, data is also processed directly by WhatsApp Business. This includes the following data categories:

  • Usage data (interests, access times),

  • Meta and communication data (device information, IP address)

More detailed information can be found in the WhatsApp Business privacy policy at https://www.WhatsApp.com/legal.

In addition, the above-mentioned data will be used for the following purposes within the framework of balancing interests (Art. 6 (1) (f) GDPR). The interests are specified below:

  1. Should a security incident occur in our company that affects your data, we are obliged to report the case to the data protection supervisory authority responsible for us (Art. 33 GDPR). As it is in our legitimate interest to comply with this legal reporting obligation as quickly as possible, it may happen that data relating to you is processed in the course of investigating the security incident in question. The reports of these security incidents to data protection supervisory authorities do not contain any of your personal data.

  2. As it is in our interest to ensure the security of our systems, we regularly carry out security and effectiveness tests, during which your above-mentioned data may be processed.

  3. Since it is in our interest to resolve legal disputes, we process your data for this specific purpose in such cases. It is also in our interest to retain evidence in the event of legal disputes until all relevant statutory limitation periods pursuant to §§ 195ff. BGB (German Civil Code) have expired. For this purpose, we retain the relevant data about you in accordance with these limitation periods. The deletion periods cannot be predicted in advance, as they depend on the subject matter of the dispute and the corresponding statutory limitation period, which can be up to 30 years. The standard limitation period is 3 years.

  4. Furthermore, it is in our interest to investigate suspicious cases and to pass on relevant information to law enforcement authorities in the event of a specific suspicion of criminal activity.

  5. We carry out audits, internal reviews, and other control measures (e.g., monitoring by the data protection officer) as it is in our legitimate interest to comply with legal requirements, create transparency in our business processes, continuously optimize these processes, and prevent and detect actions that are detrimental to our business. In doing so, documents or files containing your personal data may be processed.

Your Rights

You have the legal right to:

  • Information about the personal data stored about you (Art. 15 GDPR)

  • Correction and completion of your data held by us (Art. 16 GDPR)

  • Deletion (Art. 17 GDPR)

  • Restriction of processing (Art. 18 GDPR)

  • Data portability (Art. 20 GDPR)

  • Withdrawal of consent (Art. 7 GDPR) with effect for the future. The lawfulness of the data processing carried out up to the point of withdrawal remains unaffected.

  • You also have the right to express your own point of view and to contest a decision based on automated processing (Art. 22 GDPR).

  • You have the right to object to the processing of your data to protect our legitimate interests or the legitimate interests of third parties (Art. 21 GDPR) – You have the right to object to such processing at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions within the meaning of Art. 4 (4) GDPR.

  • Objection to direct marketing – You have the right to object to the processing of your data for direct marketing purposes at any time and without giving reasons.

To exercise these rights, you can 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).