Privacy Policy

Introduction

This is the Privacy Statement and Policy (“Privacy Policy”) for Commerzium Holding GmbH, a company headquartered in Hamburg, Germany, and its subsidiaries and affiliates (“COMMERZIUM”, “we”, “us”). This Privacy Policy was last updated on September 1, 2023. COMMERZIUM understands that your privacy is important to you and takes user privacy very seriously. COMMERZIUM is committed to protecting your privacy and personal information you provide or as you access and use materials on www.commerzium.com or additional websites (the “Site”) or mobile applications produced and managed by COMMERZIUM. In addition, information that you submit to COMMERZIUM in response to an email request for information or other outreach from COMMERZIUM, will be treated in accordance with this Privacy Policy. If you are a California resident, please see the California Appendix at the end of this Privacy Policy for further details on how we handle your information and how to exercise your rights. COMMERZIUM reserves the right, at its sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Sites. This Site may contain links to external sites which are not governed by this Privacy Policy. COMMERZIUM does not take responsibility for the privacy practices of any third-party sites to which we link. We encourage you to review the privacy policies of any such sites before you submit information there.

Your Acceptance of This Privacy Policy

Please read this Privacy Policy carefully. By browsing the Site or expressly consenting, where required under applicable privacy laws, you agree to be bound by this Privacy Policy.

Information Collection

COMMERZIUM collects information from you when you create your account for the Site, request copies of publications, subscribe for email newsletters and press releases, seek additional information regarding our services, and for marketing communications (e.g., via emails, applications/Apps, or social media platforms) from COMMERZIUM based on your consent, where required under applicable privacy laws. Personal information that we collect includes names, addresses, e-mail addresses, phone numbers, IP, geo location, subject areas of interest and/or demographic information. If you do not provide such information, you may not be able to create an account for the Site, request copies of publications, subscribe for email newsletters and press releases, seek additional information regarding our services or employment opportunities.

COMMERZIUM also collects information if you register for conferences and other COMMERZIUM-sponsored events, and/or take part in surveys run by COMMERZIUM. Therewith personal information that we collect includes names, e-mail addresses, IP, unique personal identifiers, subject areas of interest and/or demographic information. In addition, we sometimes aggregate demographic information, and the types of systems and browsers of users. COMMERZIUM may also conduct user surveys on the web or use technologies to provide COMMERZIUM with information on several areas, such as user identity, user surfing and viewing habits, whether users found what they were searching for, whether the Site content is relevant to user needs, and the like.

Information Use

COMMERZIUM uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce COMMERZIUM’s agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it during our business activities, including in connection with some client services, for example, to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

COMMERZIUM and its service providers may use first- and third-party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. COMMERZIUM and its service providers may collect information about whether you open or click any links in the knowledge, research, or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.

Additionally, in connection with our mobile applications, COMMERZIUM may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, COMMERZIUM may receive reports on one of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. COMMERZIUM also receives reports on certain errors occurring within mobile applications. As another example, an COMMERZIUM app may offer a personalized list of recommendations directing you to COMMERZIUM content that we think you will find interesting. Recommendations are based solely on what you have formerly viewed, selected, or entered in the app. In this example, a unique user identifier that is generated by the app helps personalize your app experience and tracks the articles that you read, the topics that you select, or the data that you enter in the app. We do not share your viewing history or trends through such app with other users or any external third parties (i.e., persons or entities that are not affiliates or third-party service providers of COMMERZIUM).

Legal Basis for Processing Personal Data

Our processing of your personal data for the purposes mentioned above is based (i) partly, on our legitimate interests in promoting and protecting COMMERZIUM, building and maintaining relationships. recruitment, and providing our services, and (ii) partly, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our Sites, and (iii) partly, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

How We May Share Information

COMMERZIUM will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. COMMERZIUM may provide access to your personal data to third party service providers engaged by COMMERZIUM to provide services related to the Sites as well as related to COMMERZIUM’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

The third parties with whom we may need to share personal information to help us provide services and products to you and to run our Site include: (i) our subsidiaries or affiliates, and (ii) our advisors and consultants, and (iii) our third-party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services, the Site security and marketing and events services, and (iv) our business partners for publications and events co-organized by COMMERZIUM and them, and (v) law enforcement bodies or other government officials in order to comply with any legal obligation or court order, and (vi) bona-fide rights owners in connection with allegations of infringement of copyright or other proprietary rights arising from information that you have posted on the Site or otherwise provided to COMMERZIUM.

Because COMMERZIUM is active globally, we may need to transfer personal information which is collected on the Site or through other means as described under this Privacy Policy across any current or future COMMERZIUM company to help operate our business efficiently. This also includes third parties located in different countries around the world, including but not limited to outside of EEA, Switzerland, UK, and the USA. These arrangements may involve your personal information located in various countries around the world. COMMERZIUM may maintain and stores personal information in systems and applications located in Europe as well as the USA or Asia Pacific where privacy laws differ. The personal information is only accessible by authorized persons or suppliers and vendors who are bound by privacy requirements, and we only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect information held in that country. In addition, the Site may be viewed and accessed anywhere in the world including countries that may not have laws regulating the use and transfer of personally identifiable information. Besides, COMMERZIUM may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Retention of Personal Information

COMMERZIUM retains your personal information for so long as is necessary to fulfil the purpose for which it was collected. The criteria used to determine our retention periods include: the length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). We may therefore retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, COMMERZIUM will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Cookies and Other Tracking Technologies

COMMERZIUM may use cookies on this Site and in our communications with you to keep track of your visit to our Site and our communications with you. A “cookie” is a small amount of data sent from a webserver to your browser and stored on your computer’s or mobile’s hard drive. Other tracking technologies work similarly to cookies and place a small amount of data on your devices to monitor your website activity to allow us to collect information about how you use our Site and our services. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions or you can visit www.aboutcookies.org which will give you more information. Once you have given your consent to use cookies, we shall store a cookie on your computer or device to remember this for next time. If you wish to withdraw your consent at any time you will need to delete our cookies using your web browsers settings. Please be advised that certain sections or functionalities of the Site may be inaccessible to you if your browser does not accept cookies. We do not currently respond to browser do-not-track signals.

Security Assurance Processes

COMMERZIUM has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized COMMERZIUM personnel and third-party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Each employee or contractor having access to any personally identifiable information is obligated to maintain its confidentiality. Despite of these, COMMERZIUM cannot guarantee that your personally identifiable information will not become accessible to unauthorized persons and COMMERZIUM cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public computer network.

Links to Third-Party Sites

COMMERZIUM may provide links to third party websites or information as a service to our users. Similarly, this Site contains links to other websites that are not operated by COMMERZIUM. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by COMMERZIUM of the third party, the third-party website, or the information contained therein. COMMERZIUM is not responsible for the privacy practices or the content of any non-COMMERZIUM websites to which we link from the Site. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our Privacy Policy. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user because of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

Participation in User Forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. COMMERZIUM is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

Compliance with Law

COMMERZIUM complies with all applicable data privacy laws. COMMERZIUM may be compelled to surrender personal user, customer or partner information to legal authorities if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state, or other applicable jurisdiction. Also, in the event of a violation of the terms and conditions of use of the Site or a violation of any restrictions on use of materials provided in or through the Site, we may disclose personal user information to our affected business partners or legal authorities.

Your Rights

In accordance with applicable data privacy laws, including but not limited to the GDPR and the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it, please follow the process outlined below and we will amend our records where appropriate. You also have the right to request that we erase your personal information, stop processing your personal information, restrict the processing of your personal information, and provide your personal information in a portable format. Shall you have such a request or would like to discuss how we process your personal data, please contact us via the email provided below.

Please note that we need you to prove who you are before we can provide you with any information. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law. In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

Unsubscribe

If you have registered for COMMERZIUM newsletter or alerts, or you receive invitations to our surveys or events, and you prefer not to receive future email communications, please contact us via info(at)commerzium.com thereon writing the subject as “Subscriptions” to unsubscribe from one or all COMMERZIUM communications.

Children

COMMERZIUM understands the importance of protecting children’s privacy, particularly in their online interactions. The Sites are not designed for or directed at children 16 years of age or younger, and COMMERZIUM does not intentionally collect or maintain personal data about anyone under this age.

Use of COMMERZIUM Sites

Your access to and use of the Site are subject to this Privacy Policy and certain other terms and conditions, contained in our Terms of Use.

California Appendix

This California Appendix applies to California residents and supplements the information provided above in the Privacy Policy. This Appendix does not apply to our job applicants, employees, or contractors where the personal information we collect about those individuals relates to their current, former, or potential role with us. If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please contact us using our Contact Form and selecting thereon “Purpose” as “Privacy” with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by COMMERZIUM, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed. In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about COMMERZIUM’s collection, use, disclosure, and sale of personal data about you including (i) the categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information, and (ii) the categories of sources from which we have collected that information in the preceding 12 months, and (iii) the commercial or business reason(s) we have collected, used, disclosed, or sold that information, and (iv) the categories of third parties to whom we have disclosed or sold that information in the preceding 12 months. Additionally, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months. You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us via info(at)commerzium.com to leave us a message. When we process your request, we require you to provide certain personal data about you to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. We may need to request additional personal information from you, such as a copy of your driver’s license, utility bill to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information. COMMERZIUM will not discriminate against you based on your exercise of any of these rights. If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information unless it is subject to your consent where required under applicable privacy laws. Please note that CPRA defines sensitive personal information as personal information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless COMMERZIUM is the intended recipient of the communication; genetic data; The processing of biometric information for the purpose of uniquely identifying an individual; Personal information collected and analyzed concerning an individual’s health; and Personal information collected and analyzed concerning an individual’s sex life or sexual orientation.

Contact

If you have any questions about our Privacy Policy or if you would like to communicate with our EU Data Protection Officer, please contact us via info(at)commerzium.com thereon writing the subject as “Privacy”. Alternatively, you can write us at:

Commerzium Holding GmbH
Heimhuder Str. 13
20148 Hamburg
Germany