CONNECTERE is a German advisory company being specialized in international expansion, cross-border investment, offshoring and Interim Management.
As part of the activities entrusted to us, including internationalization support, we pay utmost attention to the processing of personal data both of our clients and of employees and users of our services in general, in accordance with the General Data Protection Regulations.
This Privacy Policy applies in all relations between CONNECTERE and its contractors in the absence of a more specific agreement and the persons concerned (hereinafter the “data subject”).
Within this policy, the following terms have the following meanings and related terms should be interpreted accordingly:
“Personal data” means any information enabling the direct or indirect identification of a natural person CONNECTERE and/or a service provider process as “Data controller” or “Data processor” (Subcontractor).
“Hardware” means any hardware, system, equipment, tools communicated, owned by CONNECTERE or transferred or made accessible to CONNECTERE by its contractor.
“Regulation” means, for the purposes of this document, all the laws and regulations applicable in Germany with regard to the protection of personal data, that is to say, aimed at the protection of the fundamental freedoms and rights of individuals and, in particular, their right to privacy with regard to the processing of their personal data and in particular the European Data Protection Regulation No. 2016/679 (“GDPR”).
“Data subject”, “Data controller”, “Joint Data Controller”, “Processor”, “processing”, “supervisory authority”, “personal data breach”, “Data Protection Impact Assessment”(DPIA) retain the meaning assigned to them in the aforementioned Regulations.
As part of the execution of the Contract, CONNECTERE is required to know and process personal data.
CONNECTERE undertakes to comply with its legal obligations under the applicable law and the aforementioned Regulations, and to allow its contractor to comply with the applicable law and the Regulations.
CONNECTERE shall carry out all the formalities required by the regulations, or any other legal or regulatory provision applicable to the protection of privacy and personal data, with the competent authorities.
CONNECTERE adopts the technical and organizational security and confidentiality measures adapted to the risks and in accordance with the state of the art, and to provide mechanisms for managing authorizations, making it possible to limit access to DCPs to only those who have to know about them.
In any event, CONNECTERE and its contractors are each responsible for the breaches of their obligations as regards themselves.
In no case may they be held responsible for a breach committed by the other party, any solidarity being excluded.
When CONNECTERE acts as a Data processor (or subcontractor), it may not be held liable for any damage caused by the processing of personal data, unless it has not complied with its legal or contractual obligations and if it acted contrary to the Data controller’s instructions.
CONNECTERE guarantees its Data controller against any claim and/or proceeding, whatever its form, subject matter and nature, made by any third party and invoking a Data breach, exclusively related to a breach by CONNECTERE of its obligations hereunder, and/or one of its subcontractors (subsequent data processor)
CONNECTERE undertakes to intervene, at its own expense, in any amicable or judicial proceedings brought against one of its Data controllers and due to a breach by CONNECTERE itself and/or one of its subcontractors (subsequent data processor).
Media containing personal data and transmitted to CONNECTERE by the Data Controller remain the property of the Data Controller. Media containing personal data collected by CONNECTERE remain the property of CONNECTERE.
CONNECTERE undertakes to keep the personal data processed within the framework of its Contract, only within the time limit necessary for processing, plus the statutory limitation periods during which the information will be archived for any accounting complaint, tax or judicial.
CONNECTERE undertakes to:
CONNECTERE undertakes to:
The processing of personal data provided or collected is carried out with procedures and measures appropriate to protect security of data, in terms of integrity, confidentiality and accessibility, in compliance with the provisions of the applicable law. Such processing will be carried out through hard copy, electronic and IT means, and will be limited to the data which is necessary for the purposes detailed here below.
CONNECTERE mainly use the IT tools of Microsoft.
CONNECTERE processes the Data in order to allow the negotiation, the establishment and the execution of the agreements binding the parties, in order to comply with the related obligations arising from applicable law, and to enable the exercise of CONNECTERE rights in front with the relevant authorities.
The processing of the Customer Data for the abovementioned purposes is necessary for the establishment and performance of the contractual relationship between the CONNECTERE and his Contractors, as well as for the respect of legal obligations resulting therefrom.
The provision of the Contractor Data for the abovementioned purposes is a sine qua non condition for the conclusion and execution of the contract with CONNECTERE. Failure to provide such data would make the contractual relationship with CONNECTERE impossible.
As a result of its professional expertise, CONNECTERE may act as a joint data-controller or data-processer, depending on its autonomy in the context of its mission, the type and extent of the mission entrusted.
The following processing may be performed in particular:
In order to carry out the aforementioned processing, and within the framework of the stated purposes, CONNECTERE might be data Controller or might process through a data-processor:
The Personal Data of the data subjects will be retained for the time strictly necessary of the performance of the contract, and for a period of five (5) additional years from the end of the contract binding the parties to comply with the legal obligations provided by the applicable law or to ensure the possibility of the exercise or the defence of a right in court.
In accordance with the Regulation, accounting data is retained for ten (10) years.
Contractor’s Data will be processed by the subjects authorized to carry out the relevant processing by CONNECTERE. Furthermore, the data may be communicated to, and processed by, all those subjects to which such communication is necessary for the completion of the contract binding the parties and the purposes, and the completion the relevant data processing, and in particular to the following recipients:
Administrative and/or judicial authorities, on requisition.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
If CONNECTERE is Data Controller, or Data processor and need to hire a Data processor or a Sub-Data processor, he shall inform his Data Controller of the name and contact details of this Data processor or a Sub-Data processor and of his function, unless there is a definite urgency. If the Data Controller wishes to object to the proposed subcontracting, he must provide information within the month and propose another. Otherwise it shall be deemed to accept it.
In accordance with the Regulations, CONNECTERE ensures that each of its subcontractors guarantees at least the same level of Data protection as that contained in this policy and complies with the Regulations.
Each of the subcontractors undertakes to ensure at least the same level of Data protection as that contained in this policy and to comply with the Regulations.
In addition, CONNECTERE ensures that its personnel and those of its subcontractors respect the confidentiality of the information they access.
If the applicable laws to which CONNECTERE is subject, in Germany or abroad, require otherwise. CONNECTERE shall then, to the extent permitted by applicable laws, inform his Contractor of this legal requirement before processing such personal data.
In accordance with Article 35 of the European Data Protection Regulation, CONNECTERE undertakes to assist his Contractor in carrying out an Data Privacy impact assessment, in the event that the processing required by the Contract is likely to generate a high risk for the rights and freedoms of individuals.
If a treatment presents high risks for individuals, CONNECTERE undertakes to follow the Data Privacy impact assessment procedure in front of the French administrative authority, the CNIL.
With reference to the processing of the Data carried out by CONNECTERE, the data subject of the aforementioned data processing has the right to exercise at any time the following rights, provided by the Regulation (EU) 2016/679:
CONNECTERE will answer to the data subject’s request within one month, following the reception of the demand.
Where necessary, its contractors are asked to assist CONNECTERE in the replies given to the persons concerned wishing to exercise their right of access, opposition, rectification, erasure, limitation of processing, the portability of the data or to send directives concerning the post-mortem data processing. The contractors shall cooperate with CONNECTERE in the implementation of these rights.
Any data subject may exercise their rights with the CONNECTERE Data Protection Officer at the following addresses:
by posted mail:
Connectere GmbH
Schenkendorfstrasse 18a, 22085 Hamburg, Germany.
By Email: fs@connectere-int.com
A proof of identity is required in order to preserve the confidentiality of personal data. If despite all our efforts the data subject considers our response unsatisfactory, it is recalled that he/she has a right of complaint in front of the German control Authority.
CONNECTERE shall take all necessary and appropriate technical and organizational measures to ensure the confidentiality, security, availability and integrity of Personal Data and Materials, both its own and those made available by its contractors.
CONNECTERE shall take all reasonable measures to ensure the reliability of any employee, agent or service provider who may have access to the Personal data processed for the performance of the contract and, in particular, that it respects the confidentiality of the information it must know.
CONNECTERE has adopted an Information Security Program which incorporates appropriate and proportionate administrative, technical and physical safeguards, such as:
CONNECTERE undertakes to regularly audit and review the Information Security Program in order to ensure its continued effectiveness and to determine whether adjustments are necessary in light of the circumstances, including technological changes, regulatory, industry practices or threats and risks likely to affect data and Material.
CONNECTERE undertakes to answer as soon as possible to any request for information on its Information Security Program.
As soon as an incident occurs or as soon as CONNECTERE has suspicions about an incident related to a security breach or any other breach under the provisions relating to the processing of personal data, by or against him, CONNECTERE undertakes to:
CONNECTERE allows its clients to carry out compliance audits in relation to the processing of personal data, including inspections, to the extent that this Audit is notified fifteen (15) days in advance at CONNECTERE and during normal working hours.
The transfer of Personal Data to countries located outside the European Union will be carried out if and as necessary for the performance of the contractual relationship, or for the implementation of measures taken at the request of the data subject prior to entering into the contract, or as long as the transfer is necessary to ascertain, exercise or defend a right before judicial authorities, or if the data subject has explicitly provided the consent to the transfer, or to protect his/her vital interests, where he/she is physically or legally incapable of giving consent.
In the event of additional transfers of personal Data, CONNECTERE will carry out such transfers only:
CONNECTERE stops to process the personal data carried out under subcontracting at the end of the contractual relationship.
CONNECTERE stops processing as soon as possible and either destroys the processed data, or returns the media containing it to its contractor, according to the option determined, and removes the concerned data from its systems.
CONNECTERE shall retain the Personal Data provided by the Contractor only to the extent required by applicable law and shall ensure that such data is only processed for the purpose or purposes specified in the applicable law requiring or necessitating their retention.
CONNECTERE undertakes to keep the processed data only within the time limit necessary for processing, plus the statutory limitation periods during which the information will be archived for any accounting, tax or judicial complaint.
In order to guarantee the quality of its services and to ensure the highest possible quality of its website, the company CONNECTERE, may be required to process personal data of the User when browsing the website www.connectere-int.com and the General Conditions of Use of our website and the Cookie Policy are available online at www.connectere-int.com
This Privacy Policy is subject to change. CONNECTERE will publish any new version on its website or provide it upon first request.
For any information about the rights of the data subject and to exercise them, as well as for any issue related to the processing of personal data, the Data Protection Officer can be contacted by sending an email to fs@connectere-int.com