Data Privacy

• How can you contact us?
• How do we define certain terms?
• Which personal data are processed by us?
• Why and on what legal basis do we store personal data?
• How do we use cookies, analysis and tracking tools as well as social media registrations?
• To whom do we disclose your personal data?
• How do we work together with partners for you?
• What do we use international partners for?
• What adjustments can you make regarding data protection?
• How can you revoke your consent?
• What rights do you have?
• How do we protect your personal data?
• What possibilities do minors have for using our services?
• What other information is important?

Introduction

The present data protection regulations have the purpose of informing you regarding the processing of personal data at our company. We hereby comply with our duties from the European Data Protection Basic Ordinance (EU-DSGVO, EU 2016/679), in particular Articles 13 and 14, as well as Article 26. Sect. 2 and the Telemedia Act (TMG).

Please read the present regulations carefully. Should you have further questions, please contact us.

For Partner Tech Europe, protection of your privacy and thus of your personal data, is top priority at all times.

The present regulations describe our handling of this information on you, which may constitute personal data.

In this document we also explain how we use cookies and analysis tools on our entire website.

We abide at all times by the applicable Data Protection Law and the present Data Protection Regulations. We only disclose data in cases listed in the present regulations.

How can you contact us?

You can reach us at the following address:

Partner Tech Europe GmbH

Beim Umspannweg 10

22844 Norderstedt

Our Data Protection Representative can be reached at:

Goalgetter GmbH

data-privacy@partner-tech.eu

Willhoop 3

22453 Hamburg

How do we define certain terms?

Personal data

These are information which concern a specific or identifiable physical, living entity. However, this does not include information on legal entities.

Which personal data are processed by us?

When you visit our websites, show interest in us/conduct business with us we process different data. They may be directly or indirectly personal, i.e. with the effect of other data sources. Much of this data is recorded in pseudonymized or anonymized form. This includes the following information:

Data categories:

• Account data
• Personal data
• Address data
• Bank data
• Contact data
• Support ticket data

Information when visiting our websites:

When you visit our website, we may store information on the region from which you are retrieving the page, information on your device, operating system and browser, on the use of our site and where applicable, if you have already visited us.

When you open a contact enquiry or support ticket on our website, we process the corresponding data provided by you such as e.g. contact data, address data.

Support enquiries:

When you contact us, e.g. in order to place a support enquiry, we store your data on this enquiry such as e.g. contact data, data on your hardware and software and log-data. Beyond this, you may provide us with files for inspection for handling the support case.

Why and on which legal foundation do we store personal data?

Processing purpose:

We process your data regardless of whether they can be allocated to a person or not, for the following purposes:

• In order to comply with our contractual duties toward you.
• In order to facilitate convenient and easy use of our website.
• For administrative purposes.
• In order to offer you optimized advertising and product information on our products optimized for you.

Contract initiation and performance

Generally, we only store data which we need for the fulfillment of our contractual duties toward you.

Consent

In some places, it is possible that we offer data processing on the basis of consent. In such cases, we advise you separately of this circumstance and offer you the opportunity to give your permission to processing by us.

In these cases, we specify the purpose of the data processing and inform you on your right of revocation.

Legitimate interest

There is also the possibility of processing data on the basis of our legitimate interest. We are obligated in this context to disclose our interest and to weigh our interests and yours. This is the case in the following process:

Marketing lists – We process your contact data known to us, in order to inform you on product developments and innovations through marketing campaigns. Our interest here is to inform (potential) customers on our company, thereby securing our business activity.

Birthday greeting – We process your birthday information known to us, in order to congratulate you on this day. Our interest in this is in fostering our customer relationship.

Storage duration and deletion deadlines

We store the personal data only to the extent necessary for fulfillment of the purpose. The length of storage will be based on the legal provisions and duration of the contract.

Should the data no longer be used they will be anonymized and/or deleted within the scope of statutory provisions.

If you should have your data deleted, please be advised that we will immediately block your data, but that due to technical restrictions it may take up to 16 days until we have deleted all data completely.

Please be further advised that after confirmation of the order for deletion, there will no longer be any possibility of recovering your data.

How do we use cookies, analysis and tracking tools?

When you use a product or service for the first time, cookies will be uploaded to your browser. Your browser may be identified through the cookies so that our website can be displayed correctly. Furthermore, we deposit cookies at several places on our website in order to analyze the use of our website and to thereby optimize it.

For marketing purposes and in order to make your visit to our website more user-friendly, we use Google Analytics & Pardot.

Google Analytics & Pardot

To whom do we disclose personal data?

There will be no disclosure of your personal data to third parties for reasons other than those cited below.

We only disclose your personal data to third parties if:

• You gave your express consent to the underlying processing,
• This is permitted by law and is necessary for performing our contract with you,
• Disclosure of the data is based on a statutory obligation and
• Disclosure of the data is based on a special interest and there is no reason to assume that you have an interest in non-disclosure of your data that is predominantly worthy of protection.

We disclose data on the above grounds to the following recipients/categories of recipients:

• Employees (internal and external)
• IT-infrastructure service providers
• Payment processors, factoring companies
• Service providers for support handling
• Software service providers
• Providers of analysis tools
• Other service providers

What do we use international partners for?

We use a global network of IT infrastructure to render our services such as e.g. computer, cloud-based servers, networks and software solutions.

These partners are domiciled in different countries, in part also outside of the European Union. The same data protection level as in the European Union is not always prescribed by law and established in these countries. For this reason, we took a number of measures pursuant to SDVO provisions, in order to ensure the highest degree of protection possible for your personal data. These are:

• Cooperation with companies in a country recognized by an adequacy decision by the European Union
• Cooperation with companies according to the EU-US-Privacy-Shield
• Cooperation with companies on the basis of the EU standard contract clauses
• Cooperation with companies on the basis of agreed guarantees

We have these measures guaranteed by our partners within the scope of statutory regulations.

Beyond this, in special cases there is the possibility of disclosing the data on the basis of your explicit consent.

Which adjustments can you make with regard to data protection?

On our website you have several options regarding which data you communicate to us. It may very well be possible that through the change of settings/failure to enter information, specific services no longer function properly.

How can you revoke your consent?

If you gave your consent to specific instances of data processing, e.g. subscription to a newsletter, you have the right to revoke this consent, also partially. Please contact us in this case.

Should the processing of the data be carried out on the basis of weighing of interests pursuant to Art. 6 Sect. 1 lit f DSGVO, you also have the right here to lodge an objection against the processing if there are reasons arising from your specific situation or it concerns direct advertising.

In the case of direct advertising, you have a general right of objection without being required to provide details on the specific situation. Please notify us of your objection in textual form.

Which rights do you have?

Subject to the proviso of potential legal restrictions, you have the following rights which you may exercise:

The right to information, correction, deletion, restriction of processing, data transferability and objection.

Please be advised here that, as prescribed by law, we reserve the right to corresponding identification and to any further measures for the definite inspection of the identification.

Right to information:

If you would like information on the personal data being stored by us, please inform us of this in textual form. For security reasons and due to regulations, we may pseudonymize specific data such as credit card information.

Right to correction:

In the administration area of our software, you are offered an overview of the master data stored by us, such as name, e-mail address and address. Should you determine that this information is not accurate, you can change it yourself. For all other correction requests, please contact us in textual form.

Right to deletion:

Should you wish to have your data deleted, please inform us in textual form. We will delete your data in accordance with the statutory provisions.

However, we would already like to point out here that on the basis of statutory provisions we are obligated to store specific data for a longer period, such as the preservation periods for accounting documents of currently 10 years (Tax Ordinance) or for safeguarding guarantee claims for five years.

We further advise you that we will immediately freeze your data but that due to technical restrictions it can take up to XX days until we have finally deleted the data.

Please be further advised that after confirmation of the deletion order, it is no longer possible to recover your data.

Right to restriction of processing:

You have the right to restrict the processing of data. Please tell us the affected data categories from your perspective and the reasons for your request. We will review the facts thoroughly and inform you of the result.

Right to data transferability:

Please inform us in writing which data you want to transfer to whom. We will review your request immediately and inform you of the result.

Right of complaint:

Should you be dissatisfied in the context of data protection, you have the right to file a complaint with the relevant supervisory agency for data protection in your country. For Partner Tech Europe it is e.g.

The Hamburg Representative for Data Protection and Freedom of Information

Klosterwall 6

20095 Hamburg.

How do we protect personal data?

In order to protect your personal data, Partner Tech Europe took measures compliant with data protection law and the latest technical regulations in the sector. The latter are continuously revised and adjusted where necessary. The objective is to protect your data against accidental or willful manipulations, partial or entire loss, destruction or unauthorized access by third parties.

Communication is encrypted according to the SSL procedure (Secure Socket Layer) for the transmission of data between our websites, applications and our backends.

We protect the systems and processing through a series of technical and organizational measures. This includes data encryption, pseudonymization and anonymization, logical and physical access restriction and control, firewalls and recovery systems, integrity test.

Our staff is trained on a regular basis for handling sensitive personal data and subjected to compliance with data secrecy in accordance with the legal provisions.

What possibilities do minors have for using our services?

Our products and services may not be ordered and installed by minors.

What other information is important?

Change of the present data protection principles

The present data protection regulations are revised at irregular intervals in order to adapt it to the latest developments in the company, our products and services, the statutory provisions and societal developments.

As per: May 25, 2018