ECOM EUROPE LIMITED and its wholly owned and operated global affiliates (together “ECOM”) are committed to compliance with privacy laws and legislation in the countries in which it operates, as well as respecting generally the privacy rights of the individuals. This privacy statement explains what personal data ECOM collects or otherwise processes about you, either through our direct interactions with you (e.g.,as a customer or a visitor to our websites) or through your interactions with our Internet services or applications, as well as how and why we use(process) that data. This statement covers the following topics.
Via interactions with our Internet site ECOM.EU.
This data is collected in order to:
You provide some of this information directly, for example when registering on a website. We collect other data through your interactions with our websites and services using technologies like cookies and methods for obtaining usage and device data. For more information about the technologies, such as cookies, used and your choices regarding them, see the “Cookies” section.
Data is collected at your consent through your use of the site or explicitly via consent requests. When asked to provide personal data, you may decline. If you decline to provide information required to obtain a product or service or access a feature, you may be unable to use that product, service,or feature.
The data collected depends upon the nature of your interaction with ECOM and the products, services,and features you use, as well as any decisions you make about providing data, including decisions through privacy settings that you may set on your browser or device. Categories of data collected may include the following and apply with respect to both customer representatives and non-customers:
Contact Information and Name.
This data includes first and last name, email address, postal address, telephone number, company name, bank details, shipping addresses and personal photo.
Login Information and Credentials.
If you use any of our online services, you may be asked to create an account and provide a login name, password, and similar security information for authentication and account access.If you interact with ECOM or an online service provider used by ECOM to process employment applications, we collect information relating to your job history, educational history, resume,and related information used to evaluate candidates for employment with ECOM.
Device and Usage Data. ECOM collects information about the device you use to access our sites, communities,and portals,and the interactions of you and your device with our web properties, services and applications. That personal data includes the Internet Protocol address (IP address) associated with your computer or device, the domain name of your Internet Service Provider, your device type and identifiers, browser type, operating system, the content or pages you view on the ECOM sites, time spent on ECOM sites,and similar usage and device information. For more information about the technologies, such as cookies, used and your choices regarding them, see the “Cookies” section of this statement.
ECOM uses the personal data that it collects for three basic purposes
1.Operation of our business
Operation of our business, including providing, maintaining, developing,and improving our products and services (including identification and mitigation of security threats on the Internet) and providing recruitment services;
The data collected by ECOM both through interaction with you directly and through your interactions with our services is used to perform essential business operations and provide, maintain,and improve our products and services; including operating and
maintaining our platform, improving performance, development of new features and capabilities, research, and customer support. Business operations uses include, for example:
Fulfillment of Transactions/Contractual Obligations.
We use data to respond to requests from current and prospective customers, visitors to our sites, applicants, and other interested parties.
Personalization of Your Experience on Our Sites.
We use the data collected to provide you with a personalized experience on our websites, communities, and portals, such as providing you with content in which you may be interested and making navigation on our sites easier. The data also is used to generate statistics about the usage and effectiveness of our sites and our service offerings, personalize your experience,and tailor our interactions with you.
We use data to provide you with technical support as requested. We also use data collected to troubleshoot and identify errors in our platform and services.
Product Development and Improvement.
We use data in the development of new products and services,and to improve and implement new features in existing products. Logged Personal Data and other traffic data is used, for example, to derive and compile information relating to the type, nature, content, identity, behavior, signature, source, frequency, reputation,and other characteristics of malicious Internet traffic and activity.
We use data to detect and prevent potential fraud and security risks to our platform and to our visitors and customers
In connection with a job application or inquiry, whether advertised on an ECOM websites or on a third-party platform, you provide us or such third-party service providers with personal data about yourself, such as a resume and contact information. We may use this data within ECOM in order to address your inquiry or consider you for employment purposes. Unless you tell us not to do so, we will keep your personal data for future consideration.
2.Managing and supporting our customer relationships
Managing and supporting our relationship with our customers. This information is used to support our contracts and provide support for our services, communicate with customers, sell new services and features, troubleshoot issues,and other customer relationship related matters.
3.Communications, including promotional communications
We use data we collect to communicate with you, whether you are a visitor, prospective customer, existing customer, job applicant, or other interested party.
We use the personal data collected from your interaction with the sites to deliver marketing communications, special offers, or advertisements that may be of interest to you either directly or via third-party service providers.
As part of any communications, we offer you the opportunity to choose whether or not we can use your personal data in this way. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included in each email you may receive. Some of our offerings may be co-branded, as they are sponsored by both ECOM and third parties. We share data with these third parties for promotional purposes. We encourage you to familiarize yourself with such third parties’ privacy policies to gain an understanding of the manner in which they will handle personal data about you.
5.Customer Surveys and Service Improvements.
As part of our customer relationship with you, we contact you (except in cases when you choose not to be contacted by us) via the personal data provided asking you to participate in our satisfaction surveys or in market research surveys. We use such surveys to improve our service offering and business operations to better serve you.
ECOM shares personal data among our wholly owned and controlled affiliates and subsidiaries globally. We also share data with vendors or agents working on our behalf for the purposes described in this statement. These companies or organizations must abide by our data privacy, confidentiality,and security requirements and are prohibited from using the data for any other purposes. ECOM may share your data with your consent or as may be necessary to complete any transaction, fulfill a request,or provide you with a requested product or service either directly or through your interaction with one of our customers. ECOM will share, transfer, access, disclose,and preserve personal data to the extent required, in our discretion, that such is necessary for:
Protection of the Rights and Property of ECOM:
We use and share the personal data you provide to protect the rights or property of ECOM, our business partners, third-party service providers, customers, or others when we have reasonable grounds to believe that such rights or property have been or could be affected.
Compliance with Applicable Law:
We use and share personal data as required to comply with applicable law or regulation, respond to proper law enforcement requests or other valid legal process, or to comply with applicable government reporting obligations.
Circumstances may arise where, whether for strategic or other business reasons, ECOM decides to sell, buy, merge,or otherwise reorganize businesses in one or more countries. In such cases, we may share the personal data collected within ECOM, with ECOM third-party service providers, or other third parties as reasonable to proceed with the negotiation or completion of a merger, acquisition, sale, or other corporate transaction.
In all cases, ECOM will seek reasonably appropriate protections for your personal data when sharing it with third parties and we share it only if the recipient agrees to comply with this privacy statement or has in place substantially similar privacy policies regarding the treatment of personal data and only after execution of a data protection agreement or a non-disclosure agreement.
ECOM is a global organization with business processes, management structures,and technical systems that cross borders. As such, we share the personal data within the ECOM group and with our business partners, third-party service providers,and other third parties, and therefore transfer your personal data to countries in the world where we do business
Legal Basis for Processing of Personal Data
ECOM processes personal data for a number of reasons. In all cases, ECOM ensures that such processing is legal, fair, and reasonable. The various processing activities are justified by varying legal bases under the GDPR and similar laws.
Data Processed for Promotional Communications
In those cases where data is collected in order to provide promotional materials or communications, ECOM’ processing is based upon the consent of the individual.
Data Processed to Provide a Service, Feature,or Functionality of a Website or Portal
In those cases where you are accessing or using a feature or service provided by ECOM, the basis for ECOM’s processing is either to provide a service requested by you or, when consent is requested on the website or portal, your consent.
Processing of Logged and End User Personal Data
Where Logged Personal Data is processed in order to provide, improve,and develop services and functionality, the legal basis for such processing is ECOM’s legitimate interest in providing services to its customers,and improving and developing service to support its business objectives and provide benefit to its customers and Internet end users.
Data Processed to Support ECOM Necessary Business Operations
Where ECOM processes personal data in order to support necessary business operations such as site operations and security, recruitment, site and service analytics, relationship management, and global operations, ECOM processes such data pursuant to its legitimate interest in maintaining viable and efficient business operations and support of necessary business functions.
In all cases of data processing, ECOM considers the impact on the rights and freedoms of the individuals whose data may be part of the processing,and ensures that its processing activities do not contradict or place at unreasonable risk any such rights or freedoms.
ECOM maintains administrative, technical, organizational,and physical measures designed, taking into account the nature of the data and the processing, the state of the art, the costs of implementation,and the potential for impact to the rights and freedoms of individuals whose data is being processed, to protect personal data in accordance with this statement and applicable laws against loss, and unauthorized access, use, alteration, and disclosure, Such measures include, by way of example, encryption in transit, two-factor authentication, and strict access controls. We also require that our third-party service providers protect personal data against unauthorized access, use, and disclosure as required under applicable laws.
The retention of personal data collected depends on the purpose it has been collected for and the systems used to process the data. For example, we will retain your account data for our sites and communities for as long as your account is active. With respect to Logged Personal Data collected as a result of your interactions with a website or services, ECOM will retain such personal data generally for no more than 365 days,and often for a shorter period than that. Similarly, customer data will be retained as long as required for the customer relationship. Please note that where applicable we will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.