1. What information does this document contain for you?
The purpose of this policy is to inform users transparently about the data processing during your visit to our social media profiles and fan page(s), so that you are aware to what extent we may process your personal data when you visit our Company social media profile(s) and fan page(s), regardless of whether you are registered or logged in to the different social networks we use.
2. Who is responsible for the data processing?
According to ECJ ruling dated 5 June 2018 on social media presences and in compliance with article 26 GDPR, TKE is acting in a Joint Controllership together with the platform providers Facebook and LinkedIn when processing personal data in fan page(s).
2.1. TKE is represented by:
TK Elevator GmbH E-Plus-Straße 1 40472 Düsseldorf Germany E-Mail: dpo@tkelevator.com
3. Scope and disclaimer of liability for this privacy statement.
3.1. This privacy statement applies exclusively to the use of TKE fan page(s) when obtaining statistics produced by Facebook and/or LinkedIn from visits to the page(s) and, to the use of TKE social media profile(s).
3.2. It should be pointed out that the existence of joint responsibility does not necessarily imply equal responsibility of TKE and the platform providers involved in the processing of personal data. We have no influence on the scope, type and purpose of the processing of your personal data by the platform provider of the social media services and can inform you only according to our level of knowledge. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. For more information about the data processing by Facebook and LinkedIn when using their social media platforms view Facebook's policy here and view Linkedin’s policy here.
4. Purpose of the processing and personal data processed.
4.1. Processing purposes by TKE: The purpose of data processing by us on our social media profiles is to present our company to Facebook and LinkedIn users and people who visit our Company Profile(s).
If you voluntarily contact us via our social media profile(s), we will process your personal data to respond to your inquiries and fulfil your request, including to contact you if necessary. The legal basis for the processing of your personal data in this context is your consent (Art. 6 para. 1 (a) GDPR).
We can also communicate with you following the interactive options these social media platforms provide us, for the purpose of brand management, increasing of visibility, customer and prospective customer communication as a legitimate interest within the meaning of Article 6 paragraph 1 point (f) GDPR.
The operators of the social media platforms have no influence on the processing of your data by TKE in the context of customer communication or competitions, therefore for such processing we act as solely controllers.
The data entered by you on our pages, such as comments, videos, pictures, likes, public messages, etc., are published by the platform providers and are not used or processed by us for other purposes at any time and, we do not have any control over this information and therefore the processing is regulated by the social media platform(s) according to their privacy policies (see section 3.2.).
4.2. Processing purposes jointly by TKE and social media platforms: TKE as an administrator of fan page(s) hosted in Facebook and LinkedIn gives these social media platforms the opportunity to place cookies on the computer or other device of a person visiting our fan page(s).
In this context the creation of fan pages on social media platforms involves the definition of parameters by TKE, depending on the target audience and the objectives of managing and promoting our activities, which has an influence on the processing of personal data for the purpose of producing statistics based on visits to the fan page(s).
Consequently, TKE as administrator of these fan page(s) hosted on social media platform(s) contributes to the processing of personal data of visitors to our page(s), and as we are in some way involved determining the purposes and means of the processing of personal data of visitors to our Company Profile(s), we have a joint responsibility relationship with the aforementioned social media platforms.
Our social media fan page(s) usually can be accessed online independently of you having a user account with the relevant platform or not. But in either case, your data will be processed by the social media platform.
Each time the social media platform is accessed, your IP address will be collected and stored. Usually, a cookie will also be placed on your browser, which will record your visit and further data about your visit to the social media platform.
The use of cookies is intended on the one hand to improve the advertising systems of the social media platform(s) and, on the other hand, the use of cookies allows the social media platform(s) to provide us with statistics that enable us to control and improve our marketing activities.
Although the social media platform(s) provide us with data collected using cookies exclusively in anonymous form, the compilation of these statistics is based on the previous processing of personal data.
The legal basis for the processing purposes is your consent given to the social media platform(s) via the cookie setting when visiting the social media platform(s) Art. 6 para. 1 (a) GDPR.
4.3. Disclaimer: We would like to highlight that we have no influence on the social media platform(s) terms of use, privacy and cookie regulation, neither the web tracking methods of the platform(s). Moreover, note that the social media platform(s) use your profile and behavioural data in accordance with its usage and data protection regulations to evaluate your habits, personal relationships and preferences. TKE has no influence on the processing or forwarding your data by the platform(s) operator.
5. How long will your data be stored?
5.1. If you voluntary contact us via our social media platform(s) the information will be processed as long as necessary to fulfil your request and no longer than three (3) months after we receive your request. This retention period is only applicable to the information we may need to transfer to our IT-systems, to handle your request appropriately outside of the social media platform(s). Nevertheless, depending on your request the retention period may vary. For more information see section 5 of our Privacy Policy.
5.2. We do not have any influence on the storage period or the criteria for determining the storage period of the information specified in section 4.2. Therefore, this information should be provided by the social media platform(s) in their respective Privacy Policies (see section 3.2).
6. Who receives your data?
6.1. Unless the disclosure is mandatory for legal requirements, the information specified in section 4.1., will be processed within our Company only by persons and departments (e.g. recruitment department, sales department, marketing department, etc.), who need such information to fulfil your request.
6.2. Additionally, the information specified in section 4.1., can be processed within our Group of Companies (Corporate/business area/group companies), if they perform centralized data processing tasks for the Group's affiliated companies (e.g. centralized IT applications). The transmission of personal data to TK Elevator Group is carry out under the legitimate interest of TK Elevator Group (recital 48 GDPR).
6.3. Regarding the processing purposes specified in section 4.2., we do not have access to personal data that is processed in the context web tracking, but to the summarized page views in the form of an anonymized statistical analysis. Since we do not have access to personal data, we cannot share them with third parties. For information about recipients and any transfer of your data to a third parties by the social media platform(s), please check their privacy policies (see section 3.2).
7. Does my data get transferred outside the European union?
7.1. TK-Elevator group have located undertakings outside EU/EEA, therefore your data can be transferred outside Europe, for such data transfers standard contractual clauses have been adopted (Article 46 paragraph 2 lit. c GDPR).
7.2. Regarding the processing purposes specified in section 4.2., if necessary, your use of the platform may result in the processing of your data in a third country (outside the European Economic Area). For more information on the processing of your data in a third country, over which TKE has no influence, please refer to the respective Privacy Policies of the social media platform(s) listed in section 2.
8. Which data protection rights can you claim as the person affected?
8.1. Regarding the processing purposes specified in section 4.1., you have the right to access, to rectification, to erasure, as well as other rights, or request more information about the data processing by contacting the email address dpo@tkelevator.com. You can find additional information about your data subject rights in section 7 of our Privacy Notice.
8.2. Regarding the processing purposes specified in section 4.2., the options for exercising your rights to prevent these web tracking methods or to withdraw your consent can be found in the respective Privacy Policies of the social media platform(s) listed in section 2.
TK Elevator
