Euler Hermes, a member of the Allianz Group, is the world’s leading provider in trade-related credit insurance solutions with branches and affiliates throughout the world. Euler Hermes provides B2B insurance products and services to help customers around the globe to trade with confidence and develop their businesses safely.
This privacy notice pertains to the following legal entities:
Euler Hermes and Euler Hermes Hong Kong Services Ltd
Suites 403-411, 4/F, 12 Taikoo Wan Road, Taikoo Shing, Hong Kong
(“Euler Hermes”, “we, “us” or “our”)
At Euler Hermes, your privacy is important to us and we want you to feel comfortable visiting our site. This privacy notice explains the kinds of personal data we collect about you, how and why we collect and use it and how long we keep it. We also explain your rights to access, correct, or object to the processing of this data (including requesting deletion, subject to applicable laws and regulations).
The terms of this privacy notice are subject to any additional terms, disclaimers or other contractual terms you have entered into with Euler Hermes such as client privacy statements or notices, and any applicable mandatory laws and regulations.
Please read this notice carefully. And in case you have any questions, please contact us privacy.apac@eulerhermes.com
1. General Information
1.1 This section pertains to customers, brokers, agents and third parties, as well as individuals who visit our websites.
1.2 Is Euler Hermes a “data controller”? What does that mean?
1.3 Yes, Euler Hermes is a “data controller” as defined by applicable laws and regulations (specifically, the EU General Data Protection Regulation). This means that Euler Hermes is the legal entity in control of the personal data it collects and is required by law to ensure policies, processes and procedures are in place to safeguard this data and respect the rights of the individuals whose data is collected.
What kind of personal data does Euler Hermes collect about you?
Depending on what information you provide or preferences you select, Euler Hermes may collect the following categories of personal data about you:
· Data you provide us, e.g. when you sign up for our services, personal information such as your last name, first name, gender, email address, telephone number, job title, or company name.
· When you visit our website, our web server automatically records details about your visit including:
- IP address;
- the website from which you visited us;
- the type of browser software used;
- the Euler Hermes Website pages that you visit; and
- the date and duration of your visit to our Website.
· If you visit our website, we collect information about you by using cookies. A cookie is a small piece of data that is stored on your device and allows us to re-identify your browser when you visit our site again. We use cookies to provide you with a user-friendly, safe and effective website experience by tailoring our services to your needs and interests, e.g. by customizing your browser experience or delivering (third party) advertisement targeted to you. If you want to learn more about cookies, please go to the cookie section below (2.2).
· For the purposes indicated below, we will process personal datawe obtain from third parties (e.g. information services providers) or publicly available sources (e.g. commercial registers).
1.4 For which purposes and on which legal basis does Euler Hermes use your personal data?
We use your data for the following purposes and on the basis of
· your consent, to
- provide, maintain, improve, and develop our services and tailor them to your needs and interests (e.g. to offer you customized advertising);
- communicate with you;
- inform and advice you on products of Euler Hermes (e.g by sending you advertisements); and
- to conduct research and analysis with regards to our business relations.
· the preparation and/or performance of a contract with you, to
- prepare offers for our products, deliver our services to you and fulfill our mutual contractual obligations;
- set up and maintain your user accounts, for technical support or for other related purposes;
· our legitimate interests, to
- manage technical administration, research and development of the Euler Hermes Website;
- provide, maintain, improve, and develop our services and tailor them to your needs and interests (e.g. to offer you customized advertising);
- detect and prevent fraud;
- enhance the security of Euler Hermes’ IT systems for the benefit of all our users; and
- communicate with you.
· compliance with legal obligations to
- abide with law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities, where it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our policies or terms.
If we use your data for any other purposes than described in this policy, we will inform you about such other purpose and obtain your consent where required.
1.5 Where will your personal data be processed?
Personal Data collected by Euler Hermes may be processed both inside and outside of the European Union (“EU”) and the European Economic Area (“EEA”), subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them.
Please note that EU / EEA Member States and other countries all have different laws regarding the protection of personal data. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred to may be different (or less protective) from those in your country of residence. For example, the circumstances in which law enforcement can access personal data may vary from country to country.
Whenever we transfer your personal data for processing outside of the EEA, we will implement effective transfer mechanisms (e.g. EU Standard Contractual Clauses or Binding Corporate Rules) to ensure an adequate level of data protection.
1.6 Who will have access to personal data collected through the Euler Hermes Website?
We will ensure that your personal data is processed in a manner that is compatible with the purposes specified above. For the specified purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:
Other Euler Hermes group companies;
Authorized agents and third party service providers.
For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:
Other Euler Hermes group companies;
Authorized agents, service providers, and research analysis agencies; and
Facilitators, consultants or experts managing communications and Euler Hermes sponsored events.
Finally, we may share your personal data in the following instances:
With law enforcement agencies, government and regulatory bodies to meet applicable legal or regulatory obligations.
1.7 How long do we keep your personal data?
We will not retain your personal data longer than necessary to fulfil the purposes for which it was collected for or to fulfil legal obligations, or as permitted by law, e.g. to defend legal claims. Afterwards, we will delete your personal data. The individual retention periods depend on the type of personal data and the purpose of its processing.
1.8 What are your rights in respect of your personal data?
To the extent permitted by applicable data protection laws and regulations, you have the right to:
· access personal data held about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period;
· request the update or correction of your personal data so that it is always accurate;
· obtain your personal data in an electronic format for you or for another controller;
· request the deletion of your personal data if it is no longer needed for the purposes for which they were collected or otherwise processed;
· restrict the processing of your personal data in certain circumstances, for example, where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
· object to the processing of your personal data on specific grounds relating to your particular situation that overrides our compelling legitimate grounds for the processing;
· withdraw your consent at any time where your personal data is processed with your consent, without affecting the lawfulness of processing based on consent before its withdrawal or where there is another legal basis for processing your data (e.g. overriding legitimate interests); and
· file a complaint with the data controller and/or the relevant data protection authority.
· you may exercise these rights by contacting us and providing your name and email address with appropriate identification document to permit us to identify you as well as the purpose of your request using our Data Subject Access Request Form.
2. Websites
2.1 How does Euler Hermes collect your data?
On its websites, Euler Hermes collects only the personal data that you voluntarily provide in online forms or that you otherwise allow us to collect according to the cookie preferences you selected when you first accessed our website. You have the right to withdraw your consent at any time, and if you do so we will discontinue the processing of your data collected on this website. You can withdraw your consent .
A cookie is a small piece of data that is stored on your computer or mobile device and allows the website to "remember" your actions or preferences over time. We use cookies to ensure the proper function of our website and to facilitate your access to it by collecting information on your device and preferences (e.g. your device and your browser). Additionally, we collect information on how you interact with our and our partners’ services, like advertising services. In principle, you can also use our websites without cookies. If you want to use our website fully and conveniently, you should accept those cookies. You can change your cookie settings, e.g. to withdraw your consent, at any time.
There are several types of cookies:
(a) Session Cookie (or “temporary cookie”)
A session cookie allows us to store your action during your browser session (e.g. your login data). Session cookies are erased when you close your browser or exit our website.
(b) Persistent Cookie (or “tracking cookies”)
A persistent cookie is stored on your device in between browser sessions. These cookies help us to remember your preferences or actions every time you visit our website until the expiry date of the cookie. These cookies are also used to keep you logged onto our website. As soon as the cookie is deleted, you need to enter your login credentials again.
(c) Third-Party Cookie
These cookies are set by a third party separate from our website, for example to provide advertisements like banners for third-party products or social media buttons.
On our website, we use the following cookies:
3. Third Parties
When providing our customers with trade-related credit solutions, we may collect information about you and your company to assess and monitor our own risk and to collect debts. We collect information from third parties or publicly available information. Additionally, we might collect information that you directly disclose to us. We collect data regarding:
· Commercial entities: trade sector, name, names of the representatives (e.g. directors, board members), and information regarding your creditworthiness (e.g. payment and risk incidents),
· Sole traders or other closely held businesses: name, email address, address, trade sector, legal form, names of the representatives (e.g. directors), and information regarding your creditworthiness (e.g. payment and risk incidents).
4. How can you contact us?
If you have any queries about your personal data, you can contact us at privacy.apac@eulerhermes.com
5. How are social media plug-ins used on the Euler Hermes Website?
The Euler Hermes Website uses the following social media plug-ins ("plug-ins"):
Share button on Facebook, powered by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA;
Tweet button, powered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA;
Share Button on LinkedIn, operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States.
All plug-ins are indicated with the brand names of the respective operators Facebook, Twitter and LinkedIn ("Operator"). To increase the level of data protection and in accordance with applicable laws and regulations, we have implemented the additional programs via a ‘2-click solution’. This procedure ensures that when you visit the Euler Hermes Website, no direct connection of your browser to the servers of the Operator is established. Only if you activate the plug-ins by clicking on them and thereby grant your consent to the data transfer, your browser establishes a direct connection to the server of the respective Operator. The content of the plug-ins is then transmitted by the Operators directly to your browser and integrated by them into the website.
By accepting the plug-in, the Operator receives the information that your browser has accessed the Euler Hermes Website. If you logged into your account when you visited the Allianz Website, the Operator can connect your visit to your account directly. If you interact with the plug-in, e.g. by clicking on the Facebook button, and the Tweet button or the LinkedIn "Share" button, the data will be transferred directly from your browser to the Operator and saved by the Operator. In addition, the information will be published on the relevant social network or on your Twitter account and will be visible to your contacts. If you do not want this data transfer to the Operators, you must log out of your respective account before you click on the plug-ins and activate them. XING AG uses your data only to offer the shared functions (e.g. calculation / counter display) and not to store your personal data or to evaluate your user behaviour.
For more information on the purpose and scope of data collection, processing and use, please refer to the privacy statements below:
Facebook: https://www.facebook.com/about/privacy
Twitter: https://twitter.com/privacy
LinkedIn: https://www.linkedin.com/legal/privacy-policy
6. How oftern do we update this privacy notice?
We regularly review this privacy notice and make changes to it from time to time. We will ensure the most recent version is available here and we may additionally notify you directly (e.g via email) in the event of significant changes. This privacy notice was last updated on 12 July 2019.