Consent to the processing of personal data and its withdrawal
If your personal data is processed on the basis of your consent, you are entitled to withdraw this consent at any time, electronically to e-mail gdpr@alvao.com or in writing to the address of the ALVAO registered office listed in the Contacts section. Consent can also be withdrawn via a link in the newsletter. If you withdraw your consent and there is no other legal reason for processing your data, ALVAO will delete your personal data or anonymize it.
Recipients of your data
If ALVAO does not process personal data itself, the processing may only be carried out on behalf of ALVAO by data processors based on a data processing agreement concluded with ALVAO in accordance with the GDPR (e.g. Microsoft Corporation, Google LLC, October CMS, HubSpot, and other providers of cloud services or software tools).
If you access social networks (such as Facebook, Instagram, LinkedIn) or the YouTube platform via our website, activating the respective button will automatically transmit your personal data to the relevant service provider. The scope of personal data transmitted is determined by the respective provider, who is also responsible for the protection of the personal data you have shared.
ALVAO will not transfer personal data to countries outside the European Union or to international organizations. However, this is with the exception of possible storage of data within cloud storage on servers in countries outside the European Union, which cannot be ruled out with regard to the conditions of the cloud storage operator. In such a case, the security of personal data will be ensured on the basis of the relevant adequacy decision of the European Commission, or by the use of standard contractual clauses issued by the European Commission in Decision 2021/914 of 4 June 2021, or according to the relevant subsequent implementing decision of the European Commission. Personal data may also be disclosed to the following third parties (recipients):
- providers of professional services, such as lawyers and tax advisors, bound by a statutory or contractual obligation of confidentiality,
- persons who have a legal reason for accessing personal data (e.g. tax authorities, law enforcement authorities or other supervisory authorities with legal authorization to access information), or
- other persons if it is necessary to protect ALVAO’s rights.
The nature, purpose and timescale of data we process
1. If you are our customer, supplier or other business partner
If you are a legal entity, this information applies to the processing of personal data if you transfer personal data of natural persons to ALVAO. Please refer to the section “Personal data of third parties”.
ALVAO, as a personal data controller, will process the personal data specified in the contract made between you and ALVAO, or in other documents prepared by the parties in connection with this contract, as well as personal data that ALVAO may obtain in connection with the performance of the contract or its conclusion. In particular, the following personal data will be processed:
- identification and contact data such as name and surname, date of birth, ID and VAT number, e-mail address, telephone number, billing information, account number;
- or such other data as necessary for the conclusion and performance of the contract.
ALVAO will process personal data for the following purposes:
a) For entering into a contract, i.e. for the implementation of measures prior to concluding a contract, within the meaning of Art. 6 para. 1 (b) GDPR. For this purpose, personal data will be processed until the Contract is entered into or until there is absolutely no doubt that the Contract will not be entered into.
b) For the performance of the rights and obligations of the Controller arising from the Contract within the meaning of Art. 6 para. 1 (b) GDPR. For this purpose, personal data will be processed for the duration of the contractual obligations.
c) For the purposes of the legitimate interest of the Controller within the meaning of Art. 6 para. 1 (f) of the GDPR to protect ALVAO’s rights related to the contract, its conclusion and performance, in particular to be able to demonstrate, if necessary, how and to what extent the contract was performed. For this purpose, personal data may be processed for the duration of the obligations arising from the contract and further for the period corresponding to the relevant limitation periods, usually for a maximum period of another 11 years from the termination of the obligations under the contract. This period is suspended if you exercise any right related to the contract with ALVAO or a public authority, until the substantive decision of the competent public authority on the exercise comes into force. You can object to the processing of personal data for this purpose in accordance with Art. 21 GDPR.
You are not legally obligated to provide ALVAO with personal data for the purposes listed above. However, if the personal data are not provided, it will not be possible to enter into and properly perform the contract and the related obligations and rights of the Controller.
Personal data of third parties
Thereto, ALVAO asks you to ensure that if you transfer personal data of a third natural person to ALVAO, such as your employee, who is to be the contact person for the purpose of performing the contract, that the personal data is transferred to ALVAO in accordance with the GDPR. In particular, it is necessary to ensure that this third party is informed in accordance with the GDPR that their personal data will be transferred to ALVAO and for what purpose.
The Controller will process these personal data for the purpose for which they were transferred to him, for example, for the purpose of communicating with you in the case of personal data of a contact person, for the necessary period of time to achieve the purpose of processing.
The Provider uses Microsoft Corporation as a cloud technology provider (Microsoft Azure Services) for the Online Application including the involvement of Microsoft tools using artificial intelligence, in particular Microsoft Azure AI services and Microsoft Copilot for Microsoft 365. Accordingly, any Personal Data stored or processed through the Online Application shall be processed through Microsoft Corporation and, where applicable, its subcontractors.
The Contracting Parties agree that when providing the Services to the Client, the Provider is bound by the obligations under Article 15 of this Contract only to the extent that Microsoft Corporation is bound to the Provider under the Microsoft Corporation License Terms, in particular, but not exclusively, under the Universal License Terms for Online Services (General License Terms for Online Services), accessible under the Microsoft Corporation website, currently: https://www.microsoft.com/licensing/terms/product/ForOnlineServices/all. The Client agrees to the involvement of Microsoft tools using artificial intelligence (in particular Microsoft Azure AI Services and Microsoft Copilot for Microsoft 365) and acknowledges that the responsibility for the processing of data and Personal Data in such case lies with Microsoft Corporation. The Provider undertakes to use Microsoft Corporation's services in accordance with their terms and conditions published on Microsoft Corporation's website, in particular the Provider shall use the Azure OpenAI Service in accordance with the Code of Conduct for Microsoft Azure OpenAI Service available on Microsoft Corporation's website, currently: https://learn.microsoft.com/en-us/legal/cognitive-services/openai/code-of-conduct.
2. If you are a visitor to a website with a web address of https://www.alvao.com
Cookies:
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ReCAPTCHA
Our website may use the reCAPTCHA service provided by Google LLC (“Google”) to protect against automated spam and abuse. ReCAPTCHA is a security feature that ensures our website interacts only with real users, not automated bots.
You will be informed in the relevant section of our website when reCAPTCHA is in use. If you fill out a form or interact with a field secured by the reCAPTCHA service, you consent to the processing of additional personal data, particularly your interaction with our website (e.g. mouse movements and clicks), technical data about your device and browser (including your IP address), and a risk assessment generated by the reCAPTCHA service, which helps determine whether the user is likely a bot or a genuine user.
Personal data processed by the reCAPTCHA service is handled by Google in accordance with its Privacy Policy and Terms of Service.