Scope of the General notice
Schiberg is made up of different legal entities, details of which can be found here https://schiberg.com/#address. This General notice is issued on behalf of the Schiberg so when we mention “Schiberg”, “we”, “us” or “our” in this notice, we are referring to the relevant company in the Schiberg responsible for processing your data.
This Schiberg General notice aims to give you information on how Schiberg collects and processes your personal data and tells you about your privacy rights and how the law protects you. It is important that you read this General notice together with any other privacy notices 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. These specific privacy notices can be found by clicking on the applicable heading provided above. This General notice supplements the other notices and is not intended to override them.
Our website is not intended for children and we do not knowingly collect data relating to children. This notice does not form any part of the contract to provide services.
Data Controller of your personal data
The “data controller” means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you.
Since Schiberg is made up of different legal entities, the entity who will be the controller for your data is dependent on the situation where your personal data is collected. The following entities will be Data Controllers in relation to you:
- Schiberg affiliate that you are interacting within the specific situation, for example, the Schiberg affiliate that is organizing the event you are participating to or the Schiberg affiliate who is the employer in the recruitment process you taking part in.
Schiberg of companies (“Schiberg”) is committed to protecting the privacy and security of your personal information, in accordance with the applicable privacy legislation.
This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
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). We collect, use, store and transfer different kinds of personal data about you depending on the situation. For more specific information on the processed data, please see the specific privacy notices provided on this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the limited cases where we do process such data, we do this in accordance with the applicable legislation.
We use different methods to collect data from and about you including through direct interactions, automated technologies or publicly available sources.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We will only use your personal information when the law allows us to.
We will use your personal information in the following circumstances:
- Where you have given consent to the processing of your personal information for one or more specific purposes.
- Where the processing of your personal data is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where we need to comply with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure and we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest [or for official purposes].
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing within Schiberg
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise and for system maintenance support and hosting of data.
Schiberg entities acting as data controllers towards you are Schiberg and the Schiberg affiliate as defined in Scope of the General notice / Data Controller of your personal data of this General notice. Other Schiberg entities, if any, shall operate as data processors processing your personal data on behalf of the data controllers.
Third parties acting as data processors
We transfer your data with third-party service providers (including contractors and designated agents). All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information and are not allowed to process your personal information for their own purposes.
Third parties acting as data controllers
We may disclose your personal information also with third parties acting as data controllers where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so. This can be for example when
- explicitly requested by you
- there is a legitimate purpose for the disclosure, such as when we are facilitating a joint event or conference with a third party and have informed you that the data will be shared with such third parties
- we are conducting a merger, acquisition or another corporate transaction
- we need to comply with any legal and mandatory obligation, or to enforce and protect the rights, property, or safety of Schiberg , our clients, or others.
We share your personal data within the Schiberg. This will involve transferring your data outside the European Economic Area (EEA). In addition, our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us at email@example.com, if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised 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 requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive information on how we process your personal data and a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have 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 email@example.com. 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 legitimate basis for doing so in law.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
The contact details of other data controllers responsible for your personal data can be found here [https://schiberg.com/#address].
Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at firstname.lastname@example.org.
You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us directly in the first instance.
Changes to the Privacy notice
Schiberg reserves the right to amend this General Privacy notice and specific privacy notices at any time, for any reason, without notice to you, other than the posting of the amended privacy notices on this website. You must review this Privacy Notice from time to time for any amendments.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.