1WorldSync Privacy Policy

Last Updated: May 23, 2018

I. Introduction

II. Definitions

III. Data Controller

IV. Use Of Personal Data

V. Additional Information for EU Citizens

Information About Your Right of Objection – Art. 21 GDPR

 

I. INTRODUCTION

This 1WorldSync Data Privacy Policy (“Privacy Policy”) describes the information collection practices that 1WorldSync Holdings, Inc. and its respective subsidiaries, namely 1WorldSync Inc. 1009 Lenox Drive, Suite 202, Lawrenceville, NJ 08648, and 1WorldSync GmbH, Maarweg 165, 50825 Germany (“1WorldSync,” “we,” “us,” or “our,” if not explicitly referring to one company) follow when handling Personal Data (defined below).  The Privacy Policy applies to the collection and processing of Personal Data through our websites and user applications (the “Sites”) as well as through other means (e.g., offline during a business relationship or via telephone calls).

Employment data is not subject to this Privacy Policy, but will be covered under separate policies and procedures of, and agreements among, the various 1WorldSync companies.

1WorldSync is providing its products and services globally.  This Privacy Policy applies to the handling of personal data through 1WorldSync, informing the data subject about the handling of personal data on a global scale.  As 1WorldSync is also operating in jurisdictions with specific information duties regarding the handling of the personal data (i.e., the European Union), the Exhibits to this Privacy Policy provide additional information.  Exhibit A provides additional information for data subjects from the European Union, providing specific additional information as required under the General Data Protection Regulation (GDPR).

II. DEFINITIONS

“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Data Processor” means a natural or legal person that processes Personal Data on behalf of and pursuant to the instructions of 1WorldSync.

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  Personal Data does not include information that is anonymized.  Personal Data also does not include corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address or general corporate phone number.  However, if it is combined with your Personal Data in a manner that reasonably allows it to be associated with your identity, or is otherwise considered Personal Data under applicable law, it will be treated as Personal Data under this Privacy Policy.

III. DATA CONTROLLER

1. European Union

Data Controller for Personal Data of citizens of the European Union (“EU”) is:

1WorldSync GmbH
Maarweg 165
50825 Cologne
Germany

  +49 221 93373 0
  +49 221 93373 199
  info@1worldsync.com

Contact details of our data protection officer:

Philipp Schmiereck
Brands Consulting
Inh. Bernhard Brands
Auf dem Hahn 11
56412 Niedererbach
Germany

  ps@brands-consulting.eu
  +49 6485 – 9579 763
  +49 6485 – 9579 769

 2. United States of America and Other Countries

Data Controller for Personal Data of citizens outside the EU is:

1WorldSync, Inc.
1009 Lenox Drive, Suite 202
Lawrenceville, NJ 08648
+1 866 280 4013 within the U.S.
 +1 937-610-4223 outside the U.S.
  legal@1worldsync.com

3. Website

The Data Controller for Personal Data collected and processed through the website, www.1worldsync.com, is 1WorldSync GmbH (contact details above). This does not apply for the Online Store, where 1WorldSync Inc. is the Data Controller.  The Online Store is only intended for use by non-EU users upon prior registration.

IV. USE OF PERSONAL DATA

1. Information We Collect From or About You

A. User Requests And Business Interactions

We collect Personal Data that you provide to us through our Sites, through business requests via telephone, fax or email and in connection with other business dealings we may have with you.  This includes basic contact information about you, such as your name, title, address, phone number, fax number and email address that you provide to us in this course.  It may also include information on the products or services you have shown interest in or purchased from us.  It may also include information on the company you are working for, which is then treated as Personal Data to the extent associated with your identity.  If you use a credit card to purchase a product or service from us, we also may collect information necessary to process the credit card transaction, such as the credit card type, number and expiration date.

B. Use Of Our Websites

Website Usage Information

In addition to Personal Data that you choose to submit to us, whenever you visit or interact with our Sites, we may collect or store information regarding your use of our Sites for the purpose of the technical provision of the website (“Usage Information”).  This information is typically anonymous information.  However, if it is combined with your Personal Data in a manner that reasonably allows it to be associated with your identity, or is otherwise considered Personal Data under applicable law, it will be treated as Personal Data under this Privacy Policy.

Usage Information is automatically collected for each visit of our Sites and stored in our server log files.  This information refers to the computer system of the requesting computer.  The following information is or may be collected thereby:

  • Visitors IP
  • Timestamp
  • Requested URL
  • UserAgent
  • Referring URL

General note on do-not-track-cookies

Unless you consent to the use of certain cookies, a corresponding do-not-track cookie may be set and stored by your browser. This permanent cookie is used to store the settings you have made.

Cookies

A cookie is a data file placed on your device when you visit our Sites. We use cookies to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future.  Information collected relates to technical information, such as your browser, a timestamp and a unique identifier.  Almost all browsers allow blocking of cookies in their entirety, removal of existing cookies or warning to prevent the placing of a cookie.  You can find more information on this functionality in the documentation or in the help file of your browser.  Please note that blocking of cookies might impede your use of our Sites.

Here you can manage your cookie preferences (necessary, preferences, statistics, marketing) and review which kind of cookies this website uses.

Google Analytics

If you have given your corresponding consent under the Cookie Consent Banner or this Privacy Policy, Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google), is used on this website. Web analytics services collect and evaluate data about the behavior of visitors use of web pages. For this purpose corresponding cookies are stored on your computer. The information t about your use of this website generated by cookies (such as your IP address, the subpages you visit, etc.) are usually transmitted to a Google server in the USA and stored there. However, your IP address will previously be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area, as we have preset the anonymization of the IP address. Only in exceptional cases your full IP address will be sent to a Google server in the United States and shortened there.

On our behalf, Google will process the information collected to evaluate users’ usage behavior on our website and to compile reports on website activity. The IP address transferred by your browsing software as part of Google Analytics will not be merged with other data which is owned by Google.
For more information about Terms of Use and Privacy, please see https://www.google.com/analytics/terms/gb.html and/or https://policies.google.com/privacy?hl=en.

The data transmitted to Google by setting the Google Analytics Cookie will be held for a period of 14 months. Data that is no longer required will be deleted regularly. The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 lit. a GDPR

You may revoke your consent at any time with effect for the future by preventing the storage of cookies by setting your browser software accordingly or by clicking the following button, resulting in an opt-out cookie that will prevent your future tracking by Google Analytics on our website: GOOGLE-OPT-OUT-COOKIE
We point out, however, that you may not be able to use all the features of this website if you prevent the setting of specific cookies.

In addition, you can prevent the collection of data generated by Google Analytics cookies (including your IP address) and the transmission and processing by Google in principle and beyond this website by installing the browser plug-in available under the following Download-Link: https://tools.google.com/dlpage/gaoptout?hl=en.

Pardot

We use Pardot forms or form handlers on our website and landing pages to collect information about visitors and turn anonymous visitors into identified prospects.  Pardot forms are designed and managed completely in Pardot.  Form handlers connect Pardot to our external forms so we can funnel prospect information into Pardot.  Pardot tracks visitor and prospect activities on our website and landing pages by setting cookies on their browsers.  Cookies are set to remember preferences (like form field values) when a visitor returns to our site.  Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.  Pardot sets first-party cookies for tracking purposes, and sets third-party cookies for redundancy.  Using first-party and third-party cookies together is standard in the marketing automation industry.  Pardot cookies don’t store personally identifying information, only a unique identifier.  Pardot sets first-party cookies on our tracker subdomains and Pardot domains.  Pardot uses third-party cookies on https pages and when our account doesn’t have a tracker subdomain set up.  Pardot sets three kinds of cookies:

  • The visitor cookie is composed of a unique visitor ID and the unique identifier for your account. For example, the cookie name “visitor_id12345” stores the visitor value “1010101010”, and “12345” is the account identifier. This cookie is set for visitors by the Pardot tracking code.
  • If your account tracks opt-in preferences, the pi_opt_in cookie is set with a true or false value when the visitor opts in or out of tracking.
  • A session cookie named “pardot” is set when you’re logged in as a Pardot user. This cookie isn’t set on a visitor’s browser.

GoToWebinar

On our website, we use GoToWebinar from LogMeIn Inc., 333 Summer Street, Boston, MA, USA. This software allows us to conduct online training (webinars) for customers and interested persons with personalized access as well as to verify the actual participation in such webinars. In order to register for participation in a webinar, we may need your personal information. For existing customers, the first and last name, e-mail address, telephone number, country of origin, job title, name of the employer, as well as state are collected during registration. This data will also be matched with the Pardot service, which we also use and which we describe in this privacy policy.

You can delete records created within GoToWebinar on a self-managing basis. The return and deletion of content at LogMeIn can be requested at any time via the standardized interface. In general, user content will be deleted within 30 days following recipient of a deletion request. Upon expiration or termination of your company’s 1WorldSync, your data transferred to and stored in LogMeIn will be automatically deleted after two years of inactivity. If your data is sent to Pardot for reconciliation, it will be stored for 180 days.

YouTube

On our website, we embed video-material using YouTube, YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. We use tracking cookies which track which websites a user visits. This serves the purpose of presenting relevant and appealing advertisements to the individual user and offers advertisers a more valuable placement of their advertisements. For embedding YouTube videos, the extended privacy mode is always activated, which reduces the transmission and storage of user data (including IP address, location) to a level technically required, as long as YouTube videos are not viewed. Your IP address will be transmitted to YouTube and Google servers in the US and will be saved there when you visit a website with embedded YouTube videos. However, we have no control on any further processing of your data by YouTube.

Marketo

On our website, we use Marketo,  901 Mariners Island Boulevard, Suite # 500 (Reception), San Mateo, CA 94404, USA, to create landing pages and forms. Marketo allows us to track the activity and form entry of anonymous visitors on our website and landing pages by the use of tracking cookies. This serves the purpose of addressing these visitors adequately. Data collected by Marketo includes an IP address and a user’s affiliation (suspected based on the IP address) to: company, city, state, metropolitan region, country of origin. We have ensured that an IP anonymization is activated and your IP address is therefore processed only anonymized.

Web Beacons

A web beacon is a small graphic image or other web programming code, also known as “1×1 GIF” or “clear GIF.” We may download web beacons to Your Device when you access our Sites or through email messages that we send to you. We use web beacons only to count visitors to our Sites and to count how many emails that we send are actually opened. If a web beacon is used, it does not allow the identification of the user.

Embedded Scripts

An embedded script is a programming code that is designed to collect information about your interactions with our Sites, such as which links within our Sites you click on, which type of browser or device you use (e.g., mobile or desktop version).  We use such information to enhance the user experience, such as when using a mobile version of our Sites.  This code is downloaded onto your device when you access our Sites and is deactivated or deleted when you leave our Sites.  Identification of the user does not take place.

C. Online Shop – Not Intended For Use by EU Residents

When potential customers visit the 1WorldSync Online Store, those customers are asked to register with 1WorldSync Inc. by creating a profile or, for repeat customers, updating the customer profile.  During registration, 1WorldSync requests company name, mailing address and contact information (which includes name, email and phone number) for the registrant, technical contact and a billing contact.  1WorldSync will use the technical contact information for communications from 1WorldSync and customer’s trading partners in relation to products and services the customer has requested from 1WorldSync.  When a separate billing contact is provided, 1WorldSync will use that billing contact for billing purposes only.

If a customer add 1WorldSync products or services to its cart in the Online Store, but does not complete the action, it is considered an abandoned cart.  1WorldSync records the following information for each abandoned cart – customer name, company, date of abandoned cart, product name, quantity, cost, email and company’s primary recipient.  This information is then relayed to the sales department of 1WorldSync, Inc., where the appropriate sales representative follows up to determine if the customer requires additional assistance to complete the order.

D. Information We Receive From Third Parties

We may receive Personal Data about you from third parties, such as business partners or sales referral partners, who recommend or suggest that we contact you for business purposes.  This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address.  It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business.  Upon your prior consent, we may also obtain Personal Data about you from third parties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.

2. Purposes For Which We Use Your Information

A. Business Use

We use your Personal Data primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”).  This includes to: (1) process business transactions with us that you initiate; (2) establish and maintain customer accounts so that we may provide products or services of ours requested by you or your company; (3) register you as a user of these products or services so that you may access them through our Sites or otherwise; (4) communicate with you about updates, maintenance, outages or other technical matters concerning these products or services; (5) communicate with you about data requests of other participants in our services, with whom you synchronize your data through our products or services; (6) provide you with training regarding usage of these products or services; (7) notify you about changes to any of the policies and procedures for use of these products or services; (8) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; (9) respond to questions or inquiries that you or your company may have about our products or services, and (10) send you invoices and facilitate payments for our products and services that you have used.

B. Legal Compliance

We also may use your Personal Data as required for us to comply with laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including the United States.

C. Complaints and Improvements Of Our Products or Services

We also may use your Personal Data, such as information you provide in connection with complaints or requests, internally within 1WorldSync to help us improve our products or services, or to develop new products or services in order to answer your complaints and comply with your requests.  We may also follow up with you to see, if our proposal or solution solved your complaint or request successfully, or otherwise addresses your needs.

D. Marketing Purposes

We may use your Personal Data for purposes relating to the marketing of our products and services, or those of our business partners (“Marketing Purposes”).  This includes to: (1) send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer; (2) market or promote our products or services to you, including by offering you trial or limited access to certain of our products or services; (3) solicit input from you regarding improvement of our products or services; and (4) other purposes that we disclose to you at the time we obtain your consent.  Upon your consent, we may further use your Personal Data to (1) inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services; and (2) send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services.

GoToWebinar

The legal basis for the collection of this data and the transfer to LogMeIn is Art. 6 para. 1 lit. a GDPR, based on the consent of the respective interested parties or newsletter subscribers, as well as Art. 6 para. 1 lit. f GDPR, for our justified interest in addressing product-related advertising to existing customers. You may revoke your consent at any time with effect for the future by contacting us at info@1worldsync.com.

If we obtain your explicit consent by your acceptation of the Cookie Consent Banner when accessing the website, cookies will be stored in your browser and if needed transmitted to LogMeIn’s servers when required by our login pages. This serves to technically provide you with the service, and based on your user behavior, for 1WorldSync to confirm whether you are actually participating in the webinar. To revoke your consent at any time with effect for the future and to prevent the storage of cookies you may conduct the corresponding settings of your browser software. Alternatively, you can make the appropriate settings under item “Cookies” of this Privacy Policy. We point out, however, that you may not be able to use all the features of this website in full if you prevent the setting of individual cookies.

As part of the data processing, your IP address will also be transmitted to LogMeIn for the technical provision of the service. The transfer of personal data collected to LogMeIn as a recipient in a third country (US) is conducted under the EU-US Privacy Shield, based on the European Commission’s Appropriateness Decision. You can check the certificate here.

have entered into a Data Processing Agreement (DPA) with LogMeIn. In doing so, LogMeIn is committed to process your data according to our instructions and appropriate measures have been taken to ensure the protection of your data.

For more information about LogMeIn services visit Terms of Use and Privacy Policy.

YouTube

The legal basis for the collection and processing of this data and the transfer to YouTube LLC is the consent of the user in accordance with Art. 6 para. 1 lit. a GDPR. Website tracking through tracking cookies will only take place with your explicit consent under the Cookie Consent Banner when the website is accessed. If you do not wish to consent to the tracking of your user behavior in connection with YouTube through tracking cookies, you can do so by unchecking “Marketing” in the Cookie-Consent-Manager. This will set an opt-out cookie that prevents tracking through YouTube. You may revoke your consent at any time with future effect by preventing the storage of cookies by setting your browser software accordingly or by making the appropriate settings under point “Cookies” of this Privacy Policy.

For more information about YouTube services visit Terms of Use and Privacy Policy.

Marketo

The legal basis for the use of Marketo is your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR.

Website tracking through tracking cookies will only take place with your explicit consent under the Cookie Consent Banner when the website is accessed. The cookie is stored in your browser for two years.  The information contained therein is stored for 90 days before being replaced. If you do not wish to consent to the tracking of your user behavior in connection with Marketo through tracking cookies or if you wish to revoke your consent at a later date with future effect, you can do so by unchecking “Marketing” in the Cookie-Consent-Manager. This will set an opt-out cookie that prevents Tracking by Marketo.
You can also prevent the storage of cookies by conducting corresponding settings of your browser software or make the appropriate settings under point “Cookies” of this Privacy Policy. If the Do-Not-Track setting or similar anti-tracking setting is active in your browser, we will use Marketo in a way that respects your settings and prevents the tracking.

We have entered into a Data Processing Agreement (DPA) with Marketo. In doing so, Marketo is committed to process your data according to our instructions and that appropriate measures have been taken to ensure the protection of your data.

The transfer of personal data to Marketo as a recipient in a third country (US) is conducted under the EU-US Privacy Shield, based on the European Commission’s Appropriateness Decision. You can check the certificate here.

E. Referrals

From time to time, we may receive Personal Data about you from third parties, such as business partners or sales referral partners, who recommend or suggest that we contact you for business purposes.  We receive such Personal Data because you have consented towards the third party that they might share your Personal Data with us.  If we use that information based on your consent to contact you, it will only be to see if you are interested in our products or services, or those of our business partners.  We will not use this information for other purposes without your consent.  In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.

F. Data Integrity

You are responsible for the accuracy of all Personal Data that you provide to us.  We will use reasonable efforts to maintain the accuracy and integrity of your Personal Data, and to update that information as appropriate upon your request.  We will take reasonable steps to ensure that the Personal Data we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.

3. With Whom We May Share Information

A. Within 1WorldSync

1WorldSync is an integrated global family of companies that transacts business internationally.  Accordingly, from time-to-time and subject to the provisions of this Privacy Policy governing “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES” (see below), we may share your Personal Data and Usage Information within 1WorldSync (i.e., between and among 1WorldSync and its subsidiaries).  Such information may be used by each 1WorldSync entity for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you.

B. Outside of 1WorldSync

We share your Personal Data with third parties outside of 1WorldSync only insofar as this is legally permitted or prescribed and we limit the transfer of your Personal Data to what is necessary for the respective purpose.  We share your Personal Data with the following categories of recipients: (1) payment service providers and banks, if applicable, during payment processing; (2) external service providers for sending invoices by post or email; (3) logistics service providers; and (4) collection companies and legal advisors in asserting our claims.  We also may share your Personal Data with other third parties for purposes disclosed to you and as subsequently authorized by you through your consent.  The recipients act independently with your Personal Data, which we have transmitted to them.  We will not share your Personal Data with third parties outside of 1WorldSync for their marketing purposes without your consent as required by applicable law.

In some cases, third parties receive your Personal Data as our service providers.  These third parties are acting as Data Processors, as described below, and are bound by our instructions when handling your Personal Data.  From time to time, we also may offer you the option of sharing your Personal Data with third parties, such as business partners or sales referral partners, in order to receive information and/or marketing offers from them or other persons.  If you consent to the sharing of your Personal Data for these purposes, it will be subject to the privacy policies and business practices of those third parties.  If you later decide that you no longer want us to share Personal Data with such third parties, please contact us as indicated below under the section “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES.”  We will process your request in a reasonable period of time.

C. Data Processors

We may from time to time employ Data Processors to perform services on our behalf, such as: (1) hosting our Sites; (2) designing and/or operating certain features available through our Sites; (3) sending emails and other communications relating to our products or services; (4) fulfilling and processing orders for our products or services; (5) assisting with promotions and conferences relating to our products or services, or those of our business partners; or (6) performing other administrative services for us.  We may provide these Data Processors with access to your Personal Data in order for them to complete a requested transaction or otherwise perform services for us or for you on our behalf.  Prior to allowing our Data Processors to access your Personal Data, we will enter into a data protection agreement or addendum (“DPA”) with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law as instructed by us.

D. Links to Other Websites and Applications

The Sites may contain various links to other third-party websites or applications, which may provide additional information, goods, services and/or promotions.  These third-party websites are owned and operated independently of 1WorldSync, and may have their own separate privacy and data collection practices.  We are not responsible for the privacy practices of any third party.  Therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your Personal Data with them.

E. Community Forums

Our Sites may offer message boards, chat rooms, blogs and other public areas (“Community Forums”) where you can interact with our other customers, post images, data, requests, questions, comments, suggestions or other content, including your Personal Data (“User Submissions”).  To participate in Community Forums, you may be asked to select a user name and password and/or provide us with your email-address, and to agree to the terms of participation for those Community Forums.  We use this information to identify you and to contact you, if needed, for the provision of those Community Forums.  Your password and your email address will not be visible to other users or shared with third parties.  You should be aware that any User Submissions you post to a Community Forum, as well as your user name, may be viewed by other members of that forum.  If you choose to voluntarily post User Submissions to a Community Forum, the protections of this Privacy Policy will not apply to any Personal Data included in those User Submissions.  Think carefully before you post and use caution before disclosing any Personal Data in a Community Forum.  We are not responsible for the accuracy, use or misuse of any User Submission that you disclose or receive through a Community Forum.  We might also delete User Submissions without further notice if they include harmful or inappropriate content (e.g., pornographic material, content encouraging vandalism, crime, terrorism, racism, violence or cruelty), or infringe any third party’s rights or applicable law.

F. Promotions

We may offer various promotions (“Promotions”) through the Sites or elsewhere that may require registration with your Personal Data.  If you choose to enter or otherwise participate in a Promotion, your Personal Data may be disclosed to third parties in connection with administration of the Promotion, such as in connection with winner selection, prize fulfillment and as otherwise required by law.  By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.  These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.

G. Business Transfers

1WorldSync or any part of its business, including our Sites, may be sold at some point in the future.  Should this occur, your Personal Data may be transferred to a subsequent owner, co-owner or operator of the business unit or Site.  We also may disclose and transfer your Personal Data in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process.  In all such cases, this Privacy Policy will continue to govern the use and disclosure of such information.

H. Legal Protections and Law Enforcement

Like everyone who participates in economic activities, we are also subject to a large number of legal obligations.  These are primarily statutory requirements (such as, but not limited to, commercial and tax laws), but also, where applicable, regulatory or other official requirements.  The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and investigation of terrorist financing and offences endangering assets, the fulfilment of fiscal control and reporting obligations and the archiving of data for the purposes of data protection and data security as well as verification by tax and other authorities.  Furthermore, the disclosure of Personal Data within the framework of official/judicial measures may become necessary for the purposes of taking evidence, prosecution or the enforcement of civil law claims.  We may access, use, preserve, transfer and disclose to third parties your Personal Data to: (1) satisfy any applicable law, regulation, subpoena, governmental request, or legal process if in our good faith opinion such is required or permitted by law; (2) protect and/or defend this Privacy Policy or other policies or terms of use applicable to our Sites, including investigations of potential violations thereof; (3) protect the safety, rights, property or security of 1WorldSync or any third party; and/or (4) detect, prevent or otherwise address fraud, security issues or breaches, or technical issues.  This may include allowing third parties, such as copyright owners, Internet service providers, wireless service providers and/or law enforcement agencies, to access and use your Usage Information in order to identify you.  We may take any of these steps without notice to you to the extent permitted by law.

H. Site Hosting

Our Sites and the servers on which they are hosted are operated in various countries around the world in which we conduct our business.  Thus, your Personal Data associated with our Sites may be transferred to and/or processed in a country other than that from which it was collected.  The data protection laws in those countries may differ from those of the country in which you are located.

4. Choice And Updating Your Information And Preferences

On your request, we will grant you reasonable access to your Personal Data that we hold, as well as such other related rights as are provided by applicable law.  In addition, we will take reasonable steps to permit you to correct, amend or delete your Personal Data that you demonstrate to be inaccurate or incomplete.  However, in accordance with applicable law, we may limit or deny access to your Personal Data where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the legitimate rights of persons other than you would be violated.  We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to Personal Data.

We may provide web pages or other mechanisms on our Sites through which you can correct or update your Personal Data, or elect to change your preferences regarding our future use or sharing of your Personal Data with third parties for marketing purposes.  You can also contact us to update your Personal Data or change your preferences.  Our contact information for these purposes is as follows:

If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email.  Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications.

In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Data.  We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information.  In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.  Also, if you have posted any User Submissions to a Community Forum, these communications cannot generally be removed.

5. Information Security

We will take reasonable precautions to protect your Personal Data in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We will make reasonable efforts to keep your Personal Data reliable for its intended use, accurate, current and complete.  As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information.  While we strive to secure your Personal Data, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

6. Enforcement

We will conduct periodic internal compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy.  We encourage you to raise any questions or concerns that you may have about the way we process your Personal Data by contacting us at the address set forth below.

We commit to resolve questions and complaints about your privacy and our collection or processing of Personal Data about you.  If you believe that we are not complying with the terms of this Privacy Policy or legal requirements, you should first contact us at the applicable address above, or by email at legal@1worldsync.com.  We will investigate and will do our best to internally resolve any complaints and disputes you bring to our attention regarding the use and disclosure of your Personal Data.

7. Children

The Sites are intended for business use, and we do not knowingly collect any Personal Data from children younger than the age of eighteen (18), or otherwise as prohibited by applicable law.

8. EU Data Subjects And Privacy Shield

1WorldSync, Inc. in the United States participates in the EU-U.S. Privacy Shield Framework (the “Framework”).  1WorldSync Inc.’s participation in the Framework applies to personal data received in the United States from the European Union or European Economic Area (“EU”) about former, current, or prospective corporate customer contacts (collectively, “EU Personal Data”).  We are committed to subjecting such EU Personal Data to the Framework, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  To learn more about the Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Former, current, or prospective corporate customer contacts have the right to exercise choice (opt-out) from our use of their EU Personal Data for direct marketing purposes.  To exercise this right, please follow the instructions in any direct marketing message you may have received (e.g., click the provided opt-out link in the email message or send us an email or postal mail request to opt-out in accordance the instructions provided in the direct marketing message).  We do not otherwise use or disclose EU Personal Data in a manner that is subject to choice requirements under the Framework because we do not provide EU Personal Data to third parties other than those acting as our agent to perform tasks on our behalf and we do not receive Sensitive Personal Data (i.e., Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health or sex life or sexual orientation) under the Framework.

Please contact us as specified below if you have any questions, need access to your EU Personal Data, or otherwise need assistance.  We remain responsible for our collection, use and disclosure of EU Personal Data in accordance with the Framework.  We also are responsible for third party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage.  In certain situations, we may be required to disclose EU Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If you are a European Data Subject with an unresolved complaint or dispute arising under the requirements of the Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism.  That independent dispute resolution mechanism is the International Centre for Dispute Resolution, operated by the American Arbitration Association.  For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting their website.  We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework.  In addition, under certain conditions, more fully described on the Privacy Shield website, EU data subjects may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.

Please contact us at legal@1worldsync.com if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.

9. Changes To The Privacy Policy

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law and the principles of the Framework.  We will notify the changes that we make to this Privacy Policy by posting the revised Privacy Policy on the Sites, and such changes will be effective immediately unless otherwise stated.

V. Exhibit A: ADDITIONAL INFORMATION FOR EU CITIZENS

In the following, we provide you with the additional information as required in accordance with Article 12 et. seq. of the GDPR.  This Exhibit A supplements the information provided in the main body of this Privacy Policy to the extent required under GDPR.

I. Legal Bases Of The Data Processing

In the following, we inform you about the legal bases, on which we process your Personal Data.  The Personal Data processed as well as the purposes for such processing are set out in the main body of this Privacy Policy under Section V.

1. Information We Collect From Or About You

A. User Requests And Business Interactions

When we answer your user requests or conduct business interactions with you (Business Use as indicated under the Privacy Policy, we process your Personal Data on the basis of the following legal bases:

  • for the performance of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, provided your requests relate to obtain information about our products and services or the business interactions relate to the fulfillment or implementation of a contractual relationship, and
  • to protect our legitimate interests pursuant to Art. 6 para. 1 lit f GDPR; our legitimate interest is to answer customer inquiries appropriately.

B. Use Of Our Websites

We process your Usage Information for the technical provision of our website on the basis of the following legal bases:

  • to protect our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR in order to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website and maintain information security.

C. Information We Receive From Third Parties

We process your Personal Data that we receive from third parties on the basis of the following legal bases:

  • your consent pursuant to Art. 6 para. 1 lit. a GDPR, or
  • where 1WorldSync is acting as a Data Processor for a third party providing your Personal Data to us, on the basis of Art. 28 and a Data Processor Agreement entered into with the respective third party.

2. Purposes for Which We Use Your Information

A. Business Use

We process your Personal Data for Business Use on the basis of the following legal bases:

  • for the performance of a contract or for the implementation of pre-contractual measures, pursuant to Art. 6 para. 1 lit. b GDPR.

B. Legal Compliance

We process your Personal Data for Legal Compliance on the basis of the following legal bases:

  • as required for compliance with legal obligations, pursuant to Art. 6 para. 1 lit. c GDPR.

C. Complaints and Improvements Of Our Products or Services

We process your Personal Data for the improvement or our products or services on the basis of the following legal bases:

  • to preserve our legitimate interests to remove any malfunctions and improve our products and services, pursuant to Art. 6 para. 1 lit. f GDPR.

D. Marketing Purposes

If we receive your e-mail address in connection with the conclusion of a contract and the provision of our products and you have not objected to this, we reserve the right to regularly send you offers for similar products from our range of products by e-mail.  You can object to this use of your e-mail address at any time by sending a message to the contact option described below or via a link provided for this purpose in the newsletter or e-mail, without incurring any costs other than the transmission costs according to the basic rates.

We process your Personal Data for Marketing Purposes in the above mentioned way on the basis of the following legal bases:

  • to preserve our legitimate interests to send you promotional information regarding our products and services, pursuant to Art. 6 para. 1 lit. f GDPR; and
  • in connection with Section 7 para. 3 Act Against Unfair Competition (Gesetz gegen den unlauteren Wettbewerb, UWG).

If we wish to use your Personal Data for any other Marketing Purposes, this will only be done upon your prior consent and in line with your consent.  In these cases, we process your Personal Data on the basis of the following legal bases:

  • your consent, pursuant to Art. 6 para. 1 lit. a GDPR.

E. Refferals

If we conduct referrals, this will only be done upon your prior consent and in line with your consent.  In these cases we process your Personal Data on the basis of the following legal bases:

  • your consent pursuant to Art. 6 para. 1 lit. a GDPR.

F. Data Integrity

If we conduct measures on data integrity, we process your Personal Data on the basis of the following legal bases:

  • as required for compliance with legal obligations, pursuant to Art. 6 para. 1 lit. c GDPR and Art. 5 para. 1 lit. d GDPR; and
  • to preserve our legitimate interests to process only accurate and up to date Personal Data, pursuant to Art. 6 para. 1 lit. f GDPR.

3. With Whom We May Share Information

A. Within 1WorldSync

If we share your Personal Data within 1WorldSync, we process your Personal Data on the basis of the following legal bases:

  • as required for compliance with legal obligations, pursuant to Art. 6 para. 1 lit. c GDPR;
  • to preserve our legitimate interests in acting as group of companies, efficiently and economically providing our products and services, offer you interactions in your local language, and reaching out to you on a closer geographical scale, pursuant to Art. 6 para. 1 lit. f GDPR; and
  • where one entity of 1WorldSync is acting as a Data Processor for another entity of 1WorldSync, pursuant to Art. 28 and a Data Processor Agreement entered into with the respective entity of 1WorldSync.

B. Outside 1WorldSync

If we share your Personal Data outside 1WorldSync, we process your Personal Data on the basis of the following legal bases:

  • your consent, pursuant to Art. 6 para. 1 lit. a GDPR;
  • for the performance of a contract or for the implementation of pre-contractual measures, pursuant to Art. 6 para. 1 lit. b GDPR;
  • for compliance with legal obligations, pursuant to Art. 6 para. 1 lit. c GDPR; and
  • where one entity of 1WorldSync is acting as a Data Processor for another entity of 1WorldSync, pursuant to Art. 28 and a Data Processor Agreement entered into with the respective entity of 1WorldSync.

C. Data Processor/Site Hosting

If we share your Personal Data with Data Processors outside 1WorldSync, we process your Personal Data on the basis of the following legal bases:

  • on the basis of Art. 28 and a Data Processor Agreement entered into with the respective Data Processor.

D. Promotions

If we share your Personal Data for Promotions, we process your Personal Data on the basis of the following legal bases:

  • your consent, pursuant to Art. 6 para. 1 lit. a GDPR.

E. Business Transfers

If we share your Personal Data in connection with a business transfer, we process your Personal Data on the basis of the following legal bases:

  • to preserve our legitimate interests of growing our business and deciding how the company structure of 1WorldSync will support our business’ needs, pursuant to Art. 6 para. 1 lit. f GDPR.

F. Legal Protections And Enforcement

If we share your Personal Data for legal protection or enforcement purposes, we process your Personal Data on the basis of the following legal bases:

  • for compliance with legal obligations, pursuant to Art. 6 para. 1 lit. c GDPR; and
  • to protect our legitimate interests insofar as we assert legal claims or defend ourselves in legal disputes, or we prevent or clarify criminal offences, pursuant to Art. 6 para 1 lit. f GDPR.

II. Transfers Into Third Countries

We operate our business on a global scale.  Therefore your Personal Data may be transferred to countries outside the European Union.  For example, 1WorldSync GmbH might transfer your Personal Data to 1WorldSync Inc., 1009 Lenox Drive, Suite 202, Lawrenceville, NJ 08648, U.S.A. 1WorldSync Inc. is registered under the EU-US Privacy Shield.

Furthermore we may transfer your Personal Data to recipients situated outside the European Union.  In these cases, the recipients are either situated in a country for which an adequacy decision by the Commission exists, or 1WorldSync has entered into standard data protection clauses adopted by the Commission or adopted by a supervisory authority and approved by the Commission.  You can ask the Data Protection Officer of 1WorldSync to provide you with a copy of the respective standard data protection clauses.

III. Duration of Storage

A. General

We process your Personal Data for the duration of our business relationship.  This may not only be for the time necessary to answer any user request, but may also include the initiation of a contract (pre-contractual legal relationship) and the performance of a contract, including any post-contractual obligations.

In addition, we are subject to various storage and documentation obligations, which, however, are not conclusively derived from the German Commercial Code (Handelsgesetzbuch, “HGB”) and the Fiscal Code of Germany (Abgabenordnung, “AO”).  The periods for storage or documentation specified there are up to 10 years beyond the end of the business relationship or the pre-contractual legal relationship.

Furthermore, special legal regulations may require a longer storage period, such as the preservation of evidence within the framework of the legal statute of limitations, or during the course of legal proceedings.  According to Sections 195 and following of the German Civil Code (Bürgerliches Gesetzbuch, “BGB”), the regular limitation period is three years, but limitation periods of up to 30 years may also apply.

B. Usage Information

When using our website for information purposes only, we store your Personal Data on our servers exclusively for the duration of your visit to our website.  After you have left our website, your Personal Data will be deleted immediately.

C. Cookies

Cookies installed by us are usually also deleted after leaving our website.  However, this does not apply to Cookies of Pardot.  These remain stored for the duration of 180 days.  You also have the option to delete installed cookies yourself at any time.

D. Deletion

If the Personal Data is no longer required for the fulfillment of contractual or statutory obligations and rights, is regularly deleted, unless its limited further processing is necessary to fulfill the aforementioned obligations.  In these cases, even after termination of our business relationship or our pre-contractual legal relationship, we may store and, if necessary, use your data for a period compatible with the purposes.

IV. Your Rights as Data Subject

Under the legal provisions of the GDPR you are entitled to the following rights as Data Subject, which you can assert against us:

A. Right to Information

You are entitled to request confirmation from us at any time within the scope of Art. 15 GDPR as to whether we are processing Personal Data relating to you.  If this is the case, you are also entitled under Art. 15 GDPR to receive information about such Personal Data as well as other specific information (inter alia, processing purposes, categories of Personal Data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.

B. Right to Correction

According to Art. 16 GDPR, you are entitled to demand correction of the Personal Data stored about you if it is inaccurate or incorrect.

C. Right to Deletion

You are entitled, under the conditions of Art. 17 GDPR, to request from us the deletion of Personal Data relating to you without undue delay. Among other things, there is no right of deletion if the processing of Personal Data is necessary for (1) the exercise of the right to freedom of expression and information, (2) the fulfilment of a legal obligation to which we are subject (e.g., statutory retention obligations); or (3) the assertion, exercise or defense of legal claims.

D. Right to Limitation of Processing

Under the conditions of Art. 18 GDPR, you are entitled to request from us the limitation of the processing of your Personal Data.

E. Right to Data Transferability

You are entitled, under the conditions of Art. 20 GDPR, to request from us the provision to you of the Personal Data relating to you that you have submitted to us in a structured, current and machine-readable format.

F. Right of Revocation

You have the right to revoke your consent to the processing of Personal Data at any time with effect for the future, without incurring any costs other than the transmission costs according to the basic rates.

G. Right to Objection

You are entitled to object to the processing of your Personal Data under the conditions of Art. 21 GDPR, meaning that we have to terminate the processing of your Personal Data.  The right of objection exists only within the limits provided for in Art. 21 GDPR.  In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your Personal Data despite your objection.

H. Right of Appeal to a Supervisory Authority

You are entitled to file a complaint with a supervisory authority, in particular in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of Personal Data concerning you infringes the GDPR.  The right of appeal is not prejudicial to any other administrative or judicial remedy.  The supervisory authority responsible for 1WorldSync GmbH is:

 

The supervisory authority responsible for 1WorldSync GmbH is:
Landesbeauftragte für Datenschutz und Informationsfreiheit
Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf
  +49 211/38424-0
   +49 211/38424-10
  poststelle@ldi.nrw.de

However, we recommend that you always address a complaint to our data protection officer first.  If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our data protection officer.

 

V. Scope Of Your Obligations To Provide Data

Generally, you are not obliged to provide us with your Personal Data.  However, if you do not provide this data, we will not be able to make our website available to you, answer your questions and enter into a contract with you.

VI. Automated Decision Making/Profiling

We do not use automated decision making or profiling (an automated analysis of your personal circumstances).

 

Information About Your Right of Objection – Art. 21 GDPR

  1. You have the right to object at any time to the processing of your data on the basis of Art. 6 para. 1 f GDPR (data processing on the basis of a balance of interests) or Art. 6 para. 1 e GDPR (data processing in the public interest), if there are reasons for this arising from your particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 GDPR.  If you object, we will no longer process your personal data, unless we can prove compelling and applicable reasons for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
  2. We also process your personal data in individual cases for direct marketing purposes. If you do not wish to receive advertising, you have the right to object to it at any time; this also applies to profiling, insofar as it is associated with such direct advertising.  We will take this contradiction into account in the future.  We will no longer process your data for direct marketing purposes if you object to the processing for these purposes. The objection can be made without formality and should be addressed to:

1WorldSync GmbH
Maarweg 165
50825 Cologne
Germany
+49 221 93373 0
+49 221 93373 199
  info@1worldsync.com