In accordance with this Data Protection Policy, ICE International Copyright Enterprise Germany GmbH, Lützowstraße 100, 10785 Berlin; ICE Operations AB, Box 17092, 104 62 Stockholm, Sweden; and International Copyright Enterprise Services Limited, Russell Square House, 10-12 Russell Square, London, WC1B 5EH, will Process your personal data in compliance with applicable data protection and privacy laws.
1. DATA PROTECTION DECLARATION
We take the protection and the lawful Processing of your Personal Data very seriously. The use of our Website is possible without any indication of Personal Data, however, when you engage in certain activities, such as seeking, providing and receiving information through our tools, we may ask that you provide us with personal information, such as your name, organization name, address, e-mail address, phone number and/or other identifying information.
The Processing of Personal Data shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the applicable German data protection laws, in particular the Bundesdatenschutzgesetz (BDSG) and the German Telemedia Act (Telemediengesetz, “TMG”) as well as the applicable Swedish and UK data protection laws.
By means of this data protection declaration, we inform you of the nature, scope, and purpose of the Personal Data we may Process. Furthermore, you are informed, by means of this data protection declaration, of the rights to which you are entitled.
- a) “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject” as defined below).
- b) “Data Subject” is any identified or identifiable natural person, whose Personal Data is Processed by the controller responsible for the Processing.
- c) “Process” or “Processing” is any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- d) “Consent” of the Data Subject is any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.
2. DATA CONTROLLER
Any Personal Data provided to us by you or gathered by this Website for the purposes of ICE is controlled by ICE International Copyright Enterprise Germany GmbH, ICE Operations AB and International Copyright Enterprise Services Limited (the “Data Controllers”). Details of ICE International Copyright Enterprise Germany GmbH’s Data Protection Officer can be obtained by emailing: firstname.lastname@example.org.
4. PUSH NOTIFICATIONS
We use push notifications browser add-on to allow you to opt into notifications.
You can opt-in or out at any time, simply visit the Website and click on red bell symbol (bottom left corner) to opt-in or out of notifications.
5. USE OF GOOGLE ANALYTICS
This Website uses Google Analytics, a web analysis service provided by Google Inc. (‘Google’). Google Analytics uses ‘cookies,’ which are text files placed on your computer, to help the Website analyse how users use the site. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the United States. IP anonymization is activated on this website, so your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states of the Treaty on the European Economic Area. The full IP address will be transmitted to a Google Server in the USA and shortened there only on an exceptional basis. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services to website operators relating to website activity and Internet usage. Google will not associate the IP address transmitted under Google Analytics by your browser with other data held by Google. You may prevent Google from recording the data generated by the cookie and pertaining to your use of the Website (including your IP address), or Processing these data by downloading and installing the following browser plug-in available through the following link http://tools.google.com/dlpage/gaoptout. In view of the discussion on the use of analysis tools with complete IP addresses, we wish to advise you that this Website uses Google Analytics with the expansion ‘anonymizeIp()’; therefore, only abbreviated IP addresses will be further Processed, so that a direct connection to the individual user is eliminated. For browsers on mobile devices, please click this link to, in future, prevent anonymous tracking by Google Analytics on this Website.
6. LINKS TO OTHER WEBSITES
6.1 Social media platforms and widgets
Our Website includes social media features, such as the Facebook, Twitter and LinkedIn buttons. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
6.2 Links to third-party websites
7. DATA COLLECTION WHILE USING OUR WEBSITE
In order to provide you with the services you require, we may collect Personal Data about you from our Website. This information may include, for example, your name, address, email address, phone number and details that are relevant to the services in which you are interested.
7.1 Contact via the Contact Form, E-mail or the Enquiries Form
Our Website contains information that enables a quick electronic contact to our companies, as well as direct communication with us, which also includes e-mail. If a Data Subject contacts the Data Controllers by e-mail, contact form or via the enquiries form, the Personal Data transmitted by the Data Subject are automatically stored. Such Personal Data transmitted on a voluntary basis by a Data Subject to the Data Controller are stored for the purpose of Processing or contacting the Data Subject. There is no transfer of this Personal Data to third parties.
If we receive a complaint, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the Personal Data we collect to investigate the complaint and to review the level of service we provide. We compile and publish statistics showing information such as the number of complaints we receive, but not in a form which identifies individuals. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. We will endeavour to respect any request from a complainant who would prefer information identifying him or her not to be disclosed. However, it may not be possible to handle a complaint on an anonymous basis.
7.3 Job Applications
We shall Process the Personal Data of applicants for the purpose of application procedure. All the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format. We will use the contact details you provide to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for. Your Personal Data will only be stored for the period necessary for the recruitment process unless you expressly Consent to us retaining such data for a longer period.
If you use our online application system, this will be collected by a data processor on our behalf. These data processors are third parties who provide elements of our recruitment service for us based on a contractual relationship between ICE and them. This means that they cannot do anything with your Personal Data unless approved by us. They will not share your Personal Data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Our Website includes a blog feature that enables users to upload comments in response to a blog post. We shall Process the Personal Data of users who grant Consent for us to do so by selecting the option to save Personal Data for future comments. There is no transfer of such Personal Data to third parties.
Our Website includes a feature that enables users to sign up to our newsletter. We shall Process the Personal Data of users who grant Consent for us to do so by selecting this feature. If you opt in, your Personal Data will be collected by Mailchimp, an organisation who organise and analyse the delivery of newsletters on our behalf as a data processor. Mailchimp is based outside of the European Economic Area and is compliant with the EU-US Privacy Shield (the mechanism requiring organisations to comply with data protection requirements when transferring Personal Data between the European Union and the United States). As agreed and instructed by us, and for the provision of services, Mailchimp may engage other third parties to Process your Personal Data. In the event you no longer wish for your Personal Data to be Processed by Mailchimp, please unsubscribe from our newsletter – a link to do so is provided within each newsletter circulation.
7.6 Purchase a License
When purchasing a licence on our Website, we may collect your name, email address, financial and credit card information (collected via a secure payment processor) and other information necessary to complete the order. Please note that we do not process or retain any credit card data associated with any purchase processed on the Website. Instead, your payment will be processed by a third party payment processor, Stripe Inc., who will collect, use and process your information, including payment information, in accordance with their privacy policies. For more details of Stripe’s privacy and security processes, please visit https://stripe.com/de/privacy.
Stripe’s services in Europe are provided by a Stripe affiliate – Stripe Payments Europe Limited – an entity located in Dublin, Ireland. When processing your payment, Stripe Payments Europe Limited may transfer your personal data to Stripe, Inc. in the US. To ensure the adequate protection of your Personal Data outside the EEA, Stripe has certified to the EU-U.S. Privacy Shield Framework. For further information, please consult Stripe Privacy Shield Policy at https://stripe.com/privacy-shield-policy.
8. PURPOSE OF USE
We will ordinarily only use your Personal Data to provide you a solicited service, send you information which you have requested or to otherwise respond to you. We also use and disclose general data regarding your information (which does not identify you as an individual) for the purpose of administering and developing our Website.
9. LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for Processing operations for which we obtain Consent for a specific Processing purpose. If the Processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, the Processing is based on Article 6(1) lit. b GDPR. If the Processing of Personal Data is necessary to pursue the Data Controller’s legitimate business interests of answering an enquiry submitted by the Data Subject or providing information to the Data Subject, the Processing is based on Article 6(1) lit. f GDPR.
10. DISCLOSURE OF YOUR INFORMATION
This may be, in particular, the provision of information for the purposes of Criminal Prosecution, warding off a danger or the enforcement of intellectual property rights. Where we disclose your Personal Data to a third party with your Consent, we only do so to third parties who are required to take appropriate security measures to protect your Personal Data in line with our own data protection and security policies. We do not allow our third-party service providers to use your Personal Data for their own purposes. We will not transfer your Personal Data to any third party outside the European Economic Area without a valid mechanism ensuring that your Personal Data will be protected by means equivalent to the GDPR e.g. Standard Contractual Clauses for International Transfers.
11. STORAGE AND ERASURE OF DATA
We shall Process and store your Personal Data only for the period necessary to achieve the purpose of storage, or for a longer period as far as this is permitted by the European legislator or other legislators in laws or regulations to which a Data Controller is subject to.
12. SECURITY OF INFORMATION
We will secure and protect your privacy by means of appropriate technical and organizational measures against the loss, destruction, access to, alteration or dissemination of your data by unauthorized persons. All information submitted is stored on servers within the European Union.
13. YOUR RIGHTS
Under the GDPR and additional applicable German, Swedish and UK data protection regulations and laws, you have rights as the Data Subject, which you can exercise in relation to the information we hold about you. You can request details of which Personal Data we have stored about you, at any time and, if necessary, demand its correction and/or deletion and/or restriction of Processing and/or blocking. For this purpose and/or to obtain further information about it, you may contact us at email@example.com or firstname.lastname@example.org. The same applies if you have any questions, comments or inquiries concerning the Processing of your Personal Data by ICE. If you have a complaint about the way in which we are managing and Processing your Personal Data, you also have a right to lodge a complaint with a data protection supervisory authority (e.g. Federal Commissioner for Data Protection and Freedom of Information in Germany or the Swedish Data Protection Authority in Sweden or the Information Commissioner in the UK).
14. CHANGES TO THIS POLICY