This policy is issued by the BacTrace AG (in the following also referred to as “we”, “us” or “our”) and is is addressed to individuals outside our organization with whom we interact, including visitors to this website, potential partners and other users of our services (in the following also referred to as “you”). For the purposes of this policy, BacTrace is processing your personal data. Contact details at the bottom of this site in order to answer queries about the use and processing of your personal data. We encourage you to carefully read this policy , and to regularly check this page to review any changes we might make.
2. Data Processing
I. Collection of Personal Data: We may collect the following data about you:
- When you contact us via email, telephone or by any other means.
- When you submit your resume/CV or other information to us for a job application.
- In the ordinary course of our relationship with you (e.g. personal data we obtain in the course of administering your payments).
- When you sign up for our email newsletter.
- When you visit any of our websites or use any features or resources available on or through our website. When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a website and other technical communications information), some of which may constitute personal data.
II. Creation of Personal Data: In providing our services, we may also create personal data about you, such as records of your interactions with us and details of your order history.
III. Relevant Personal Data: The categories of personal data about you that we may process include:
- Personal details: name(s), gender, date of birth / age, nationality, and photograph.
- Contact details: shipping address (e.g. for returning original media and/or storage devices), postal address, telephone number, email address, and social media profile details.
- Contact profession: status as an individual investor, analyst, broker/investment advisor, portfolio manager, banker/financing source, press/media, consultant, employee, customer/client, student, or other status.
- Views, opinions and comments: any views, opinions, and comments that you choose to send to us, or publicly post about us on social media platforms.
- Please note that the personal data about you that we process may also include sensitive personal data as defined below.
IV. Lawful Basis for Processing Personal Data: In processing your personal data in connection with the purposes set out in this policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- We have obtained your prior express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way)
- The processing is necessary in connection with any contract that you may enter into with us
- The processing is required by applicable law
- The processing is necessary to protect the vital interests of any individual, or
- We have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
V. Processing your Sensitive Personal Data: We do not seek to collect or otherwise process your sensitive personal data, except where the processing is necessary for the establishment, exercise or defense of legal rights; or we have, in accordance with applicable law, obtained your prior explicit consent prior to processing your sensitive personal data (as above, this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
If you provide sensitive personal data to us (e.g. if you provide us with hardware from which you wish us to recover data) you must ensure that it is lawful for you to disclose such data to us, including ensuring that one of the legal bases set out above is available to us with respect to the processing of those sensitive personal data.
VI. Purposes for which we may Process your Personal Data: The purposes for which we may process personal data, subject to applicable law, include:
- Our Websites: operating and managing our websites; providing content to you; displaying information to you when you visit our Websites; and communicating and interacting with you via our websites or otherwise.
- Provision of services: providing our websites and other services and communications in relation to those services.
- Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law.
- Financial management: sales, finance, corporate audit and vendor management.
- Improving our Services: identifying issues with existing Services, planning improvements to existing services and creating new services.
- Human Resources: administration of job applications.
VII. Voluntary Provision of Personal Data and Consequences of Non-Provision: The provision of your personal data to us is voluntary and will usually be a requirement necessary in order to enter into a contract with us and to enable us to fulfill our contractual obligations towards you. You are under no statutory obligation to provide your personal data to us; however, if you decide not to provide us with your personal data, we will not be able to conclude a contractual relationship with you and to fulfill our contractual obligations towards you.
3. Disclosure of Personal Data
to third parties
I. We may disclose your personal data to other entities in order to fulfill our contractual obligations towards you or for legitimate business purposes (including providing services to you and operating our websites), in accordance with applicable law. In addition, we may disclose your personal data to:
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- Third party processors (such as payment services providers, shipping/courier companies, technology suppliers, customer satisfaction survey providers, operators of “live-chat” services and processors) who provide compliance services such as checking government issued prohibited lists, located anywhere in the world, are subject to the requirements noted below in this Section 3;
- Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights, or any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offense or the execution of criminal penalties
- Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation), but only in accordance with the applicable law; and
II. If we engage a third-party Processor to Process your Personal Data, we will conclude a data processing agreement as required by the applicable laws with such third-party processor so that the processor will be subject to binding contractual obligations to: (i) only Process the personal data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.
III. We may anonymize personal data about the use of the websites (e.g. by recording such data in an aggregated format) and share such anonymized data with our business partners (including third party business partners).(D) International transfer of personal data Because of the international nature of our business, we may need to transfer your personal data within BacTrace AG, and to third parties as noted in section 3 above, in connection with the purposes set out in this policy. For this reason, we may transfer your personal data to other countries that may have lower standards for data protection than the EU due to different laws and data protection compliance requirements to those that apply in the country in which you are located.
4. Data Security
We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.
You are responsible for ensuring that any personal data that you send to us are sent securely.
5. Data Accuracy
We take every reasonable step to ensure that:
- your personal data that we process are accurate and, where necessary, kept up to date, and
- any of your personal data that we process that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your personal data.
5. Data Minimisation
We take every reasonable step to ensure that your personal data that we process are limited to the personal data reasonably required in connection with the purposes set out in this policy (including the provision of services to you).
6. Data Retention
- We maintain an ongoing relationship with you (e.g. where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed), or
II. Additionally, we will retain personal data for the duration of:
- Any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant), and
- An additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any personal data that are relevant to that claim),
III. In the event any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.
- During the periods noted above in relation to legal claims, we will restrict our processing of your personal data to storage of, and maintaining the security of, the personal data, except to the extent that the personal data needs to be reviewed in connection with any legal claim, or any obligation under applicable law.
- Once the periods above, each to the extent applicable, have concluded, we will permanently delete or destroy the relevant personal data.
(I) Your legal rights
I. Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:
- The right to request access to your personal data that we process or control, together with information regarding the nature, processing and disclosure of those Personal Data;
- If you wish to obtain a copy of your Personal Data please use the contact details provided in Section 9 below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond within an appropriate timeframe and, in any event, within any timescales required by law;
- the right to request rectification of any inaccuracies in your Personal Data that we Process or control;
- the right to request, on legitimate grounds:
- erasure of your Personal Data that we Process or control; or
- restriction of Processing of your Personal Data that we Process or control;
- the right to object, on legitimate grounds, to the Processing of your Personal Data by us or on our behalf;
- the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;
- the right to withdraw your consent to Processing, where the lawfulness of processing is based on consent; and
- the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.
- The right to request access to your personal data that we process or control, together with information regarding the nature, processing and disclosure of those personal data;
- If you wish to obtain a copy of your personal data please use the contact details provided in Section 9 below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timescales required by law;
- the right to request rectification of any inaccuracies in your personal data that we process or control;
- the right to request, on legitimate grounds:
- erasure of your personal data that we process or control; or
- restriction of processing of your personal data that we process or control;
- the right to object, on legitimate grounds, to the processing of your personal data by us or on our behalf;
- the right to have your personal data that we process, or control transferred to another controller, to the extent applicable;
- the right to withdraw your consent to processing, where the lawfulness of processing is based on consent; and
- the right to lodge complaints with a data protection authority regarding the processing of your personal data by us or on our behalf.
This does not affect your statutory rights.
II. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal data, please use the contact details provided in section 9 below.
III. If we are providing you with services based on orders, such provision of services is regulated by contractual terms provided to you. In case of discrepancies between such terms and this policy, this policy is supplementary.
What Are Cookies
For more general information on cookies see the Wikipedia article on HTTP Cookies.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The Cookies We Set
- Forms related cookies: When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
- This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However if you are still looking for more information, you can contact us through one of our preferred contact methods:
- ‘controller’means the entity that decides how and why personal data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- ‘data protection authority’means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- ‘EEA’means the European Economic Area.
- ‘personal data’means information that is about any individual, or from which any individual is identifiable. Examples of personal data that we may process are provided in section 2 above.
- ‘process’, ‘processing’or ‘processed’means anything that is done with any personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- ‘processor’means any person or entity that processes personal data on behalf of the controller (other than employees of the controller).
- ‘services’means any services provided by us.
- ‘sensitive personal data’means personal data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
9. Contact details
I. The controller in respect of whom this policy is issued is as follows:
|Company Name||Country||Registered Address|
|BacTrace BioTec AG,||Germany||Neherstr. 1, 81675 Munich|
II. If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the processing of personal data by us, please contact the contact named below:
BacTrace BioTec AG
Phone: +49 170 766 400 1