Notice of Privacy Practices for www.ellomay.com
Introduction & Purpose of This Notice
ellomay is committed to protecting the privacy and security of the personal information we gather from visitors to our website, www.ellomay.com.
This privacy notice aims to give you information on how Ellomay collects and processes the personal data provided to us through this site, including information that you provide directly, and to tell you about your rights related to that personal information. The purpose of this notice is limited to describing data gathering and processing related to www.ellomay.com and your interactions with this site. The notice does not apply to other sites or other business activities of Ellomay or of Ellomay’s subsidiaries or affiliated organizations.
Collection and Use of Your Personal Information
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The primary type of personal information we gather through this site and process is contact information. We do not gather any categories of sensitive information, such as data revealing race or ethnicity, political opinions, religion or beliefs, trade union membership, health or sex life, sexual orientation, genetic data or biometric data.
It is important that you read this privacy notice with special attention given to the specific type of processing activity that is relevant to you and your information, in addition to any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Email Alert Registration and Contact Forms
Information We Collect
We may collect, use, store, and transfer different kinds of personal data, data such as:
- Identity Data: first name, last name
- Contact Data: email address, mailing address, and telephone number.
Why We Collect This Information
The purpose of this processing is to enable Ellomay to respond to your requests made through this site for information about our services, to provide you with email alerts that you sign up to receive, and to seek your opinions about the performance of this site.
As a data controller under the GDPR, we must choose a “lawful basis for processing” personal information for each type of processing we do. In this particular type of processing, our lawful basis is your consent. By relying on your consent as our basis for this type of processing, we understand that you may revoke your consent at any time. Please see the Your Personal Data Rights section of this notice for additional details about your rights under the GDPR.
How We Collect This Information
We only collect this information through direct interactions with you through this site or your inquiries to our contact information area via email or telephone.
Who We Share This Information With
We may share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Ellomay shares this information with:
- Equisolve (our web site developer for this site)
- Email service providers (who may send email to you on our behalf)
- Cloud hosting providers (who make this website accessible on the Internet)
These organizations act as data processors for the purposes of this type of processing. These data processors operate under agreements that we have with them and they function only on instructions from us as the controller of your data.
How We Keep Your Personal Data Secure
Ellomay takes the security of all the data we hold very seriously. Preserving the confidentiality, integrity, and availability of the personal information that Ellomay gathers and uses through this site is essential to Ellomay’s role in connection with anyone interested in Ellomay and its business.
Security measures that we use include encryption, access controls, audit logs, and operational and technical policies and procedures.
We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
A cookie is a small text file which asks permission to be stored by your web browser. Once you consent to its use, the file is added and the cookie helps analyze web browsing traffic. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes, by gathering and remembering information about your site preferences.
Ellomay may use traffic log cookies to identify which pages are being visited most. This helps analyze data about web page traffic and improve the website in order to tailor it to customer needs. This information can only be used for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better user experience of our website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This kind of overall browser blocking of cookies may prevent you from taking full advantage of the website.
Disclosures of Your Personal Data
We may share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.
We may share your personal data with third parties including third-party service providers, regulatory bodies, and under valid court orders. Where we do so, we will require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We or our third-party service providers may transfer your personal data outside the EU if you are an EU resident. Where we do so, we have put in place measures to ensure your personal information is provided with adequate protection in accordance with data protection regulations.
For more information about the purposes for which we may share your data with third parties, please refer to the Collection and Use of Your Personal Information section of this notice for the circumstances and third parties that may be involved in each specific processing activity.
Ellomay will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory accounting, or reporting requirements.
We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal or regulatory requirements.
We have to keep basic information about our customers and suppliers for tax purposes for a certain period after the last transaction. In some circumstances, you can ask us to delete your data. See the Your Personal Data Rights section for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Our Role as Data Controller
For data we collect directly from individuals through www.ellomay.com, we are the controller of that data. This means that we are responsible for deciding how we hold and use your personal data when you provide it to us through this site. As a data controller, we are also responsible for directing the work of our service providers that serve as data processors for data gathered through this site.
Your Personal Data Rights
Under the European Union (EU) General Data Protection Regulation (GDPR), in effect from May 25, 2018, if you are an EU resident, you have certain rights with regard to your personal data. Ellomay must respond to a request to exercise these rights within one month.
If you would like to request details of the personal data we hold about you, please contact us at email@example.com
Under the GDPR, if you are an EU resident, you have the following rights in regard to your personal data:
- Right to be informed – you have the right to request details of how your personal data is processed. This privacy notice is a proactive document designed to meet this right.
- Right to request access – you can request copies of the personal data we hold about you. This is commonly known as a “data subject access request” or DSAR. The purpose of this request is to establish the accuracy of the personal data we hold and to check we are processing it lawfully.
- Right to request correction or rectification – if you think that some or all of the personal data we hold on you is incorrect or incomplete, you can ask for it to be corrected.
- Right to request erasure – you have to right to ask us to delete your personal data if you think that we do not have a legal reason to continue to process it.
- Right to request suspension of processing – this enables you to request we suspend processing your personal data; for example, while we establish the accuracy of the data.
- Right to object – you have the right to object to the processing of your personal data for direct marketing purposes.
- Right to request data portability – you can request that your personal data is transferred to a third party directly in a readable format.
In certain circumstances where you may have been asked for, and provided, your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.
Minors Online Privacy Notice
Ellomay does not knowingly collect personal information from minors who are under the age of 16 through the Website. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact Ellomay at the contact information set forth below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will delete such information from our files.
If you are unhappy with how any aspect of this privacy notice, or how your personal information is being processed, please contact us at email@example.com.
If you are an EU resident, you also have the right to lodge a complaint directly with the data protection authority in your country.
NOTE: The above GDPR complaint approach would only be appropriate for US-based companies that have minimal EU persons interacting with their business. If you have an actual EU presence, you would need to evaluate whether you need to establish a connection to a primary Data Protection Authority (DPA) for your business.
The first part here, with the general “report complaints here” is a good general approach, but if your business has an EU presence, you may need to appoint a Data Protection Officer (DPO) and provide that information here.
If you have any questions or comments regarding this privacy notice or this site, please contact us at firstname.lastname@example.org.
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.