Scope and acceptance
Whose data we process
ECS as data controller
Why we process your personal data
About Customer contacts and software users
How we collect your personal data
Automatic data collection tools
What personal data we process
How we share your personal data
Right to opt-out of marketing communications
Data Security and retention
How we keep your personal data secure
How long we store your personal data
ECS As a data processor
Subcontractors and export of personal data
Changes to this statement
How to contact us
This Privacy Statement applies to all business processes in ECS International bv and to all ECS International bv websites, domains, subsidiaries, cloud services and communities as well as ECS International bv branded websites (ECS International bv Sites). Service specific appendices will be found in the Terms of Service, data processing agreements or equivalent information for the specific service in question.
The Privacy Statement provides information about data processing carried out by ECS International bv when ECS International bv determines the purpose and means of the processing (ECS International bv act as data controller). It also provides information on data processing ECS International bv do on behalf of our Customers based on their instructions (the Customer as data controller and ECS International bv as data processor).
Personal data is information that can identify you as a person, such as an email address, street address or phone number etc. Processing your personal data is necessary for us to serve our Customers. Please do not use ECS International bv Sites or our services if you do not agree with how we process personal data according to this Privacy Statement.
ECS International bv process personal data about contact persons or software users tied to our Customers. In addition we process personal data about persons representing potential Customers (leads) that approach us via ECS International bv Sites or other channels. Our statement in these regards is to be found in the data controller section.
We also process data on behalf of our Customers of which the Customer controls. Our statement in these regards is to be found in the data processor section.
In this Privacy Statement data subjects may also be referred to as persons or you.
When a ECS International bv subsidiary determines the purpose and means of processing your personal data, this company act as data controller. This includes scenarios where ECS International bv collects personal data in the context of you being a job seeker, you being a representative for a Customer or Lead, or when you are a software user.
To manage our Customer relations in general and to meet our Customer commitments, ECS International bv needs information about you in your role as Customer contact person or user of a service. The purposes of processing this personal data are:
- Execute sales and contract process to Customers
- Provide requested offers on products and services to Customers
- Perform deliveries in accordance with agreements made with you or Customers
- Offer support to users of our products and services
- Improve and develop the quality, functionality and user experience of our products, services and ECS International bv Sites
- Detect, mitigate and prevent security threats and perform maintenance and debugging
- Prevent abuse of our products and services
- Process orders, invoicing, payments and other financial follow-up
- Create interest profiles in order to promote relevant products and services
- Operate user communities to educate and enable interaction between users and ECS International bv
In general, ECS International bv collects personal data directly from you or other persons linked to our Customer. These persons may be a manager or colleague. If the Customer you work for purchases ECS International bv products or services via an ECS International bv partner company, we may collect information about you from the partner company.
In some cases, we may also collect information about you from other sources. These sources may be third-party data aggregators, ECS International bv’s marketing partners, public sources or third-party social networks. ECS International bv will be able to combine personal data about you obtained from one source with data obtained from another source. This gives us a complete picture of you, which also gives us the possibility of serving you in a more relevant way with a greater degree of personalization.
ECS International bv uses different digital tracking technologies to collect information about your movements on ECS International bv Sites and when interacting with us.
Cookies and pixel tags
Pixel tags are scripts that executes when a user lands on a website or opens an email. The pixel itself is not visible and can only be seen in the HTML of the site or email. It calls an application on a server that will cause a third party cookie to be downloaded to your computer or registers that the email has been opened.
If you would like to know more about cookies and how they work, please visit www.allaboutcookies.org.
Google cookies and technologies
Google Analytics: This cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on a website. The information is depersonalized and is displayed as numbers, meaning it cannot be traced back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our websites, and strive to give you more of the things you enjoy reading and watching.
Google Analytics Remarketing: Places cookies on your computer which means that after you leave our website, Google can show you advertisements about ECS International bv that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
Google AdWords: By using Google AdWords code, we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget. This information is not personally identifiable.
Google Adwords Remarketing: Places cookies on your computer which means that after you leave our website Google can show you advertisements about ECS International bv that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
You can prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser. This Add-on is available at http://tools.google.com/dlpage/gaoptout.
Facebook Remarketing: the Facebook pixel tag places cookies on your computer which can send an alert back to Facebook telling Facebook that you have checked out the website. We then assume that you have an interest for ECS International bv and the content on this site. When visiting Facebook, you will then be exposed to information or adds with similar content. Please use your privacy settings on Facebook to limit exposure to marketing of this kind.
The type of personal data that ECS International bv process about you may be:
- Basic contact details such as name, address, telephone number and (business) email.
- Employment information such as employer, title, position including preferences and interests in professional context
- Feedback, comments or questions about ECS International bv or concerning our products and services
- Photos or video of you recorded at our premises
- Content you have uploaded such as photos, video and print screens.
- Unique user information such as login ID, username, password and security questions
- Company financial information such as bank details and credibility
- Traffic information as provided by your web browser such as browser type, device, language and the address of the website from which you arrived and other traffic information such as IP address
- Clickstream behaviour and movement on ECS International bv Sites and in our products and services
- Email behaviour such as which emails from ECS International bv you open when and how
- Other personal data contained in your profile that you have freely given away on third party social networks such as LinkedIn etc.
As data controller, ECS International bv does not process sensitive personal data about you.
Within the ECS International bv Group
As ECS International bv consists of different subsidiaries, there is a great likelihood that a Customer will conduct business with more than one ECS International bv company. It is important to us that we provide the best possible customer service and overall experience. In order to maintain a complete overview and insight into which Customers and contact persons have relations with the various companies within the ECS International bv Group, we will therefore share your personal data among our subsidiaries.
Outside ECS International bv Group
ECS International bv may also share your personal data with external third parties in the following contexts:
ECS International bv may share your personal information with our partners in the event this is legitimate from a business perspective and according to applicable privacy legislation. For example, if you purchase a product or service on behalf of your employer that ECS International bv provides through one of our partners. In this regard, ECS International bv and our partner may share personal data in order to be able to provide the product or service to the Customer.
The police and other authorities may demand the handover of personal information from ECS International bv. In these cases, ECS International bv will only hand over the data if there is a court order etc. to do so.
In connection with mergers, acquisitions or divestiture of all or parts of ECS International bv’s business, the acquiring entity, as well as its consultants, will obtain access to data managed by the ECS International bv entity/entities involved and this may in some cases include personal data. In such cases, external parties will enter into a NDA with ECS International bv.
You have the right to opt-out of receiving marketing communications from ECS International bv and may do so by either:
(a) Following the instructions for opt-out in the relevant marketing communication,
(b) Contacting us via e-mail on firstname.lastname@example.org
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from ECS International bv, such as order confirmations and notifications necessary to manage your account or the services provided to Customers.
You have the right to access your personal data by requesting an overview of the personal data we process about you and you may have a right to data portability. You also have the right to request that ECS International bv corrects inaccuracies in your personal data.
Further, you have a right to request deletion of personal data, and to restrict or object to our processing of your personal data according to this Privacy Statement or other service specific terms.
Please use email@example.com to file all requests as mentioned in this section.
Finally, you also have a right to file a complaint with the data protection authorities with regards to our processing of your personal data.
ECS International bv takes the trust you and our Customers place in us very seriously. ECS International bv is committed to preventing unauthorized access, disclosure or other deviant processing of personal data. ECS International bv shall ensure the confidentiality of personal data we process, maintain the personal data integrity and secure its availability according to applicable privacy legislation.
As part of our commitments, we utilize reasonable and appropriate organizational, technical and physical procedures and measures to safeguard the information we collect and process, taking into account the type of personal data and risk posed to you and our Customers upon breach. Since root causes for privacy breaches are most likely to be found internally, we believe that building a strong corporate culture where respect for and awareness around privacy among our employees are fundamental to ensure lawful processing and protection of your data The following measures are of particular importance in this regard:
- Data processing agreements with subcontractors that process data on behalf of ECS International bv
- Personal data is transferred and stored in secure and redundant operating environments that are only accessible to ECS International bv employees and subcontractors on a need-to-know basis
- Software users are required to verify their identity (e.g. login ID and password) before they can access or make changes to the service that is provided.
- Our premises protected by access control.
- Physical documents are stored in a confined space and access control is limited.
ECS International bv will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.
This means that ECS International bv may retain your personal data for a reasonable period after you and our Customer’s last interaction with us. When the personal data that we collected is no longer required we erase it. We may process data for statistical purposes.
ECS International bv provides many different services to our Customers. Most of our services involves processing of the Customers’ data. The purposes of processing is determined by our Customers not by ECS International bv making the Customer the data controller. ECS International bv do in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. The relation between the Customer as data controller and ECS International bv as data processor is described in our Data Pro Statement.
Customer and ECS International bv obligations
When the Customer act as data controller the Customer shall, according to applicable privacy legislation, ensure the legal grounds for processing the personal data. Further, the Customer shall assess and establish ownership to the risks posed to data subjects by processing their personal data. Another important aspect of the Customer’s duty as data controller is to comply with the information duty towards data subjects.
ECS International bv is a natural part of the Customers duties as data controller, in the sense that ECS International bv’s services constitutes parts of the processing of personal data that the Customer must ensure are compliant with applicable privacy legislation. Thus, when ECS International bv processes personal data on behalf of its Customers, we must do so in accordance with privacy legislation applicable for data processors.
In short, the Customer and ECS International bv are obligated to cooperate to ensure privacy for data subjects. ECS International bv shall provide the information necessary for the Customer to be compliant with applicable privacy legislation.
ECS International bv uses subcontractors to process personal data and may export your or our Customers data outside the EU in this regard. These subcontractors are typically vendors of software, cloud services or other IT (hosting) services.
When using subcontractors, ECS International bv will enter into a data processing agreement (DPA) with subcontractors in order to safeguard your privacy rights and to fulfil our obligations towards our Customers. When subcontractors are located outside the EU, ECS International bv ensures legal grounds for such international transfers on behalf of you or our Customers, hereunder by relying on Privacy Shield (US) or using the EU Model Clauses.
ECS International bv relies on some strategic external third parties to support our business processes and to provide our services. A list of these third parties can be obtained at firstname.lastname@example.org.
In any case, you are always welcome to request an overview and more detailed information on ECS International bv’s subcontractors, hereunder documentation of legal grounds for international transfers mentioned above.
If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.
The last update of this Privacy Statement was January 16th, 2018.