Privacy Notice（EN）

Privacy notice for visitors of this website

 

1. Introduction

1.1      Allianz Trade and Euler Hermes

Allianz Trade is the trademark used to designate a range of services provided by Euler Hermes group (referred to below as Euler Hermes). Euler Hermes,  member of the Allianz group, is the global leader in trade credit insurance and a recognized specialist in the areas of surety, collections, structured trade credit and political risk. Euler Hermes is present in more than 50 countries with 5,800 employees.

When we process information relating to an individual, such as a sole trader, a partnership or a company director for instance, this is personal data and we process this information in accordance with the applicable laws and regulations. Euler Hermes respects applicable laws and regulations in its use of personal data.

 

1.2  Scope of this privacy notice

Euler Hermes appreciates your visit to this website and your interest in our services and products. Your privacy is important to us and we want you to feel comfortable visiting our site. This privacy notice explains how and what type of personal will be collected, processed and used during and following your visits to this website, why it is collected, with whom it is shared and your rights in this regards.

This privacy notice applies to any information obtained by Euler Hermes through your use of this website. It does not apply to any websites controlled by third parties not affiliated with Euler Hermes that this website may link to. Please review the privacy statements of third party websites as Euler Hermes is not responsible for and has no influence on the content or the privacy practices of third party websites.

The terms of this privacy notice are subjected to any additional terms, disclaimers or other contractual terms you have entered into with Euler Hermes such as client privacy statements or notices, and any applicable mandatory laws and regulations.

For more information about how we process personal data where you are, work for or represent a business that has a contract with Euler Hermes, or if you are, work for or represent a third party business, please click the relevant tab on the left of this page in order to consult the relevant privacy notice. If you are a job candidate, you can consult the relevant privacy notice in the careers section of our website.

As we update this privacy notice constantly, please check it on a regular basis.

 

1.3  Data controller

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. This privacy notice applies to the following data controllers as defined by relevant data protection laws and regulations:

Euler Hermes Consulting (Shanghai) Co., Ltd 05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

 

2. Which personal data do we process?

 

2.1 When you browse this website

When you visit this website, our web server automatically records details about your visit including: IP address, the website from which you visited us, the type of browser software used, the website pages that you visit, and the date and duration of your visit to this website.

We will use these personal data for the following purposes:

• for technical administration, research and development of this website;
• to conduct research and analysis with regard to our business relations;
• for fraud prevention and detection;
• to comply with any legal obligations (e.g. tax, accounting and administrative obligations)

We inform you where we require your consent to process your personal data. Otherwise, we process your personal data to meet our legitimate business interests (including protecting our systems, and conducting market research and analysis) or where it is needed to comply with a legal obligation.

We will not retain your personal data longer than necessary to fulfil the purposes for which it was collected or to fulfil legal obligations, or as permitted by law, e.g. to defend legal claims. Afterwards, we will delete your personal data. Analytics cookies are deleted after 13 months, and cookie preferences are deleted after 6 months.

 

2.2 When you contact us through this website

When you contact us through this website (such as by filling out a web form), we may collect and process various types of personal data, including: Family name, first name, title, address, gender, contact details, job title, company name, business and/or profession, and/or shareholder number.

We only collect these data where you choose to provide us with them.

We will use these personal data for the following purposes:

• for customer and user administration and marketing;
• to maintain business relationships;
• to conduct research and analysis with regard to our business relations;
• to inform you about our events, services, products and news when you visit this website or when you subscribe to our newsletter or mailing lists;
• to facilitate compliance with securities law, public company listing requirements and related laws and regulations;
• to comply with any legal obligations (e.g. tax, accounting and administrative obligations)

We will inform you where we require your consent to process your personal data. Otherwise, we process your personal data to meet our legitimate business interests (including maintaining contact with clients, providing updates and information about Euler Hermes, organising and hosting events, and conducting market research and analysis) or where it is needed to comply with a legal obligation. In addition, we may also process your personal data to enter into a contract with you, or to perform our obligations under an existing contract with you.

We will not retain these data longer than necessary to fulfil the purposes for which it was collected or to fulfil legal obligations, or as permitted by law, e.g. to defend legal claims. Afterwards, we will delete your personal data.

 

2.3 If you are a potential customer

We may process your personal data on the basis of your consent, for the purpose of informing you of our products, services and offers.

For this purpose we may process: your name, gender, company, business, profession and/or job title, professional post address, professional email address and professional telephone number. We obtain this information directly from you.

This information will be retained as long as you wish to remain in contact. You can withdraw your consent at any time.

 

3. Cookies and social media plugins

3.1 Are cookies used on this website?

Tracking technology helps us manage and improve the usability of the Euler Hermes website, for example by detecting whether there has been any contact between your computer and us in the past and to identify the most popular sections of this website.

Based on a more detailed description on the usage of cookies our Cookies Management Tool helps you to manage your cookies preferences including providing consent. The link to the respective Cookies Management Tool you find below. You can withdraw your consent to the usage of certain cookies any time using the before mentioned tool.

When you save your cookie settings, they should also apply to your future visits to this website. However, for technical reasons beyond our control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access this website from another browser or device, your cookie settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your cookie settings when you first visit this website. If you are in a country where you are automatically required to set your cookie settings, you may be asked to set them again on a future visit.

In many cases you can also control tracking technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept tracking technologies (such as cookies) where possible. The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser.

Without tracking technologies the availability of the services provided by this website may be reduced, or parts of our website may no longer function correctly.

 

3.2. How are social media plug-ins used on this website?

The Euler Hermes Website uses the following social media plug-ins ("plug-ins"):

• Share button on Facebook, powered by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA;
• Tweet button, powered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA;
• Button Xing, operated by XING AG, Gänsemarkt 43, 20354 Hamburg, Germany;
• Share Button on LinkedIn, operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States.

All plug-ins are indicated with the brand names of the respective operators Facebook, Twitter, Xing and LinkedIn ("Operator"). To increase the level of data protection and in accordance with applicable laws and regulations, we have implemented the additional programs via a ‘2-click solution’. This procedure ensures that when you visit the Euler Hermes Website, no direct connection of your browser to the servers of the Operator is established. Only if you activate the plug-ins by clicking on them and thereby grant your consent to the data transfer, your browser establishes a direct connection to the server of the respective Operator. The content of the plug-ins is then transmitted by the Operators directly to your browser and integrated by them into the website.

By accepting the plug-in, the Operator receives the information that your browser has accessed the Euler Hermes Website. If you logged into your account when you visited the Allianz Website, the Operator can connect your visit to your account directly. If you interact with the plug-in, e.g. by clicking on the Facebook button, and the Tweet button or the LinkedIn "Share" button, the data will be transferred directly from your browser to the Operator and saved by the Operator. In addition, the information will be published on the relevant social network or on your Twitter account and will be visible to your contacts. If you do not want this data transfer to the Operators, you must log out of your respective account before you click on the plug-ins and activate them. XING AG uses your data only to offer the shared functions (e.g. calculation / counter display) and not to store your personal data or to evaluate your user behaviour.

For more information on the purpose and scope of data collection, processing and use, please refer to the privacy statements below:

• Facebook: https://de-de.facebook.com/about/privacy/
• Twitter: https://twitter.com/privacy 
• XING AG: https://www.xing.com/app/share?op=data_protection 
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
•  

4. Who has access to your personal data?

We ensure that your personal data are processed in a manner that is compatible with the purposes specified above.

For the specified purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:

• Other Allianz group companies;
• Authorized agents and third party service providers.

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

• Other Allianz group companies;
• Authorized agents, service providers that facilitate and/or provide parts of our services, and research analysis agencies; and
• Facilitators, consultants or experts managing communications and Euler Hermes sponsored events.

Finally, we may share your personal data in the following instances:

• With law enforcement agencies, courts, government and regulatory bodies to meet applicable legal or regulatory obligations, where we are legally obliged to do so.
•  

5. Where will your personal data be processed?

Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them.

Whenever we transfer your personal data for processing outside of the EEA by another Allianz group company, we will do so on the basis of the binding corporate rules (BCRs) of Allianz known as the Allianz Privacy Standard (APS) which establish adequate protection for personal data and are legally binding on Allianz group companies. The public version of the APS and the list of Allianz group companies that comply with them can be accessed here.

Where the Allianz Privacy Standard does not apply, we will instead take steps to ensure that the transfer of your personal data outside of the EEA receives an adequate level of protection as it does in the EEA. You can find out what safeguards we rely upon for such transfers (for example, EU Standard Contractual Clauses) by contacting us as detailed below.

 

6. What are your rights in respect of your personal data?

 

6.1 GDPR rights

Where permitted by applicable law or regulation, you have the right to:

• Access your personal data held about you and to learn the origin of the data, the purposes and means of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed.
• Withdraw your consent at any time where your personal data is processed with your consent.
• Update and correct your personal data so that it is accurate.
• Delete your personal data from our records if it is no longer needed for the purposes indicated above.
• Restrict the processing of your personal data in certain circumstances, e.g. where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy.
• Object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing).
• Obtain your personal data in an electronic format.
• File a complaint with us and/or the relevant data protection authority.

You may exercise these rights by contacting us and providing your name and email address as well as the purpose of your request, using our Data Subject Request form available at: Data Subject Request form

 

6.2 Residents of California

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. The section below describes these rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Euler Hermes disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, in a portable format:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purposes for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

Deletion of information

You have the right to request the deletion of your information within the rights provided by the CCPA. The right to deletion does not apply where the retention of personal information is needed to perform any of the following:

• Provide goods or services to you;
• Detect or resolve security or functionality-related issues;
• Comply with the law;
• Conduct research in the public interest;
• Safeguard the right to free speech; or
• Carry out any actions for internal purposes that you might reasonably expect

Non-Discrimination

Euler Hermes will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts, rebates, or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

The Sale of Personal Information

Euler Hermes does not sell and has not sold in the past 12 months any personal data of visitors to its websites.

7. Protection of your personal data

 

7.1 What security measures protect information collected through this website?

We have implemented reasonable technical and organizational security measures to protect your personal data collected by us via our website against unauthorized access, misuse, loss or destruction.

 

7.2  How do we treat electronic messages sent to and from Euler Hermes?

All electronic messages sent to and from Euler Hermes are protected by reasonable technical and organizational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations) to specific persons in defined functions (e.g. Legal, Compliance, Risk). All emails are disposed of after the applicable retention period has expired.

 

7.3 What should you consider when sending data over the Internet?

The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the Euler Hermes website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than in your country of residence.

Euler Hermes does not accept responsibility or liability for the security of your information whilst in transit over the Internet to Euler Hermes. In order to protect your privacy you may choose another means of communication with Euler Hermes, where you deem it appropriate.

8. How to contact us

If you have any queries about how we use your personal data, you can contact our Data Protection Officer by post or email via the details specified below:

 

Post mail:      

Data Protection officer

Euler Hermes Consulting (Shanghai) Co., Ltd

05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

 

Email:  privacy.apac@allianz-trade.com

 

9. How often do we update this privacy notice?

We constantly review this privacy notice and make changes to it from time to time. We will ensure the most recent version is available here. This privacy notice was last updated on  July 1 2022

Privacy notice for partners 

Individuals who are, work for or represent a business

having a contractual relationship with Euler Hermes

 

1. Introduction

1.1      Allianz Trade and Euler Hermes

Allianz Trade is the trademark used to designate a range of services provided by Euler Hermes group (referred to below as Euler Hermes). Euler Hermes,  member of the Allianz group, is the global leader in trade credit insurance and a recognized specialist in the areas of surety, collections, structured trade credit and political risk. Euler Hermes is present in more than 50 countries with 5,800 employees.

 When we process information relating to an individual, such as a sole trader, a partnership or a company director for instance, this is personal data and we process this information in accordance with the applicable laws and regulations. Euler Hermes respects applicable laws and regulations in its use of personal data.

 

1.2 Scope of this privacy notice

This privacy notice applies to any information obtained by Euler Hermes when you are, work for or represent a business that has a contractual relationship with Euler Hermes.

The terms of this privacy notice are subjected to any additional terms, disclaimers or other contractual terms you have entered into with Euler Hermes such as client privacy statements or notices, and any applicable mandatory laws and regulations.

For more information about how we process personal data when you visit our website, or if you are an owner, director or representative of a business, please click the relevant tab on the left of this page in order to consult the relevant privacy notice. If you are a job candidate, you can consult the relevant privacy notice in the careers section of our website.

As we constantly update this privacy notice, please check it on a regular basis.

 

1.3 Data controller

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. This privacy notice applies to the following data controllers as defined by relevant data protection laws and regulations:

Euler Hermes Consulting (Shanghai) Co., Ltd 05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

 

2. Which personal data do we process?

 

2.1 Purposes

We process your personal data for the following purposes:

• prepare offers for our products and deliver our services to you;
• fulfil our mutual contractual obligations or between Euler Hermes and the business you work for or represent;
• set up and maintain user accounts for our customers and partners and provide technical support;
• maintain business relationships and organise and host meetings and other events;
• inform you about events, services, products and news;
• conduct research and analysis with regard to our services and business relations;
• prevent and detect fraud and secure Euler Hermes and Allianz tools and systems;
• facilitate compliance with securities law, public company listing requirements and related laws and regulations;
• comply with any other legal obligations (e.g. tax, accounting and administrative obligations).
•  

2.2  Legal basis

We process your personal data based on the necessity to prepare and/or perform a contract with you, and on our legitimate business interests for the purposes set out above, including the performance of a contract with the business that you work for or represent.

We may also process your personal data on the basis of our legal obligations in order to comply with law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities, where it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our policies or terms. This include for instance the fulfilment of our “Know Your Customer” obligations.

We will inform you where we require your consent to process your personal data.

 

2.3 Data categories of personal data

These data include, where applicable:

• First name, last name, gender, title;
• Business contact details, including business address, business telephone number, business email address;
• Job title, business role and responsibilities;
• Company name, business and/or profession;
• Shareholder information.
•  

2.4 Information sources

This information is provided to us by yourself, your employer, the business you represent, or third parties.

You ensure that the relevant data that you provide to Euler Hermes is reliable, accurate, complete and up-to-date. In the event that these data need to be updated, modified or deleted, you undertake to inform Euler Hermes by written means without delay.

 

2.5  Retention duration

We retain these data as long as they are relevant to the contractual relationship and necessary to fulfil the purposes for which they were collected, or to fulfil our legal obligations, or as permitted by law to protect our legitimate business and legal interests, e.g. to defend legal claims. Afterwards, we delete your personal data.

 

3. Profiling

Article 4.4 of GDPR, defines ‘Profiling’ as any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Our services activity includes a profiling of businesses to assess credit risk through a grade circulated to our customers that are operating in B2B fields. This profiling may include automatic decision-making.

The Euler Hermes grade is an indication of our assessment of a business’ financial stability according to the available information, and predicts with 12-month probability whether a business is likely to pay invoices on time, receive credit, or whether they are subject to other specific risks.

The Euler Hermes grade may have implications in terms of insurance coverage. Depending on the grade, Euler Hermes customers will be able to benefit from an insurance cover for their credit risks. Our grade does not include any recommendation by Euler Hermes to enter into any contracts or make a delivery. Our customers are provided with appropriate documentation to understand and interpret each level of grade.

In accordance with Article 22 of the GDPR, all sole traders, one-person-companies, businesses’ shareholders, representatives and owners, in so far as they are individuals whose data have been used in the course of Euler Hermes grading activities, can obtain an explanation of the decision reached after such assessments, and they can challenge the outcome by adding to or correcting the information upon which the grade was based, by contacting Euler Hermes at the address indicated in section 1.3.

For the purpose of grading we use different models and algorithms that are constantly monitored and improved. We do not use blacklists and process no special category personal data described in Article 9(1) of the GDPR.

Our grading activity is carried out for the purposes arising from the legitimate interest of Euler Hermes to provide information as well as trade credit insurance services to its customers and more particularly to perform its obligations under the underlying  services contracts and insurance policy. As an insurer, our activity is highly regulated and supervised by competent authorities.

 

4. Who has access to your personal data?

We ensure that your personal data are processed in a manner that is compatible with the purposes specified above.

For the specified purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:

• Other Allianz group companies.
• Authorized agents, brokers and third party service providers.

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

• Other Allianz group companies.
• Authorized agents, brokers, service providers that facilitate and/or provide parts of our services, and research analysis agencies.
• Facilitators, consultants or experts managing communications and Euler Hermes sponsored events.

Finally, we may share your personal data in the following instances:

• With law enforcement agencies, courts, government and regulatory bodies to meet applicable legal or regulatory obligations, where we are legally obliged to do so.
•  

5. Where will your personal data be processed?

Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them.

Whenever we transfer your personal data for processing outside of the EEA by another Allianz group company, we will do so on the basis of the binding corporate rules (BCRs) of Allianz known as the Allianz Privacy Standard (APS) which establish adequate protection for personal data and are legally binding on Allianz group companies. The public version of the APS and the list of Allianz group companies that comply with them can be accessed here.

Where the Allianz Privacy Standard does not apply, we will instead take steps to ensure that the transfer of your personal data outside of the EEA receives an adequate level of protection as it does in the EEA. You can find out what safeguards we rely upon for such transfers (for example, EU Standard Contractual Clauses) by contacting us as detailed below.

 

6. What are your rights in respect of your personal data?

 

6.1 GDPR rights

• Where permitted by applicable law or regulation, you have the right to:
• Access your personal data held about you and to learn the origin of the data, the purposes and means of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed.
• Withdraw your consent at any time where your personal data are processed with your consent.
• Update and correct your personal data so that it is accurate.
• Delete your personal data from our records if it is no longer needed for the purposes indicated above.
• Restrict the processing of your personal data in certain circumstances, e.g. where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy.
• Object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing).
• Obtain your personal data in an electronic format.
• File a complaint with us and/or the relevant data protection authority.

You may exercise these rights by contacting us and providing your name and email address as well as the purpose of your request, using our Data Subject Request form available at: -> Data Subject Request form

 

6.2 Residents of California

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. The section below describes these rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Euler Hermes disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, in a portable format:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purposes for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

Deletion of information

You have the right to request the deletion of your information within the rights provided by the CCPA. The right to deletion does not apply where the retention of personal information is needed to perform any of the following:

• Provide goods or services to you;
• Detect or resolve security or functionality-related issues;
• Comply with the law;
• Conduct research in the public interest;
• Safeguard the right to free speech; or
• Carry out any actions for internal purposes that you might reasonably expect

Non-Discrimination

Euler Hermes will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts, rebates, or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

The Sale of Personal Information

Some personal information that we process as described in section 2 may be shared with other Allianz group companies.

 

7. Protection of your personal data

 

7.1 What security measures protect information?

We have implemented reasonable technical and organizational security measures to protect your personal data against unauthorized access, misuse, loss or destruction.

 

7.2 How do we treat electronic messages sent to and from Euler Hermes?

All electronic messages sent to and from Euler Hermes are protected by reasonable technical and organizational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations) to specific persons in defined functions (e.g. Legal, Compliance, Risk). All emails are disposed of after the applicable retention period has expired.

 

7.3 What should you consider when sending data over the Internet?

The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the Euler Hermes website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than in your country of residence.

Euler Hermes does not accept responsibility or liability for the security of your information whilst in transit over the Internet to Euler Hermes. In order to protect your privacy you may choose another means of communication with Euler Hermes, where you deem it appropriate.

 

8. How to contact us

If you have any queries about how we use your personal data, you can contact our Data Protection Officer by post or email via the details specified below:

Post mail:      

Data Protection officer

Euler Hermes Consulting (Shanghai) Co., Ltd

05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

Email: privacy.apac@allianz-trade.com

9. How often do we update this privacy notice?

We constantly  review this privacy notice and make changes. We will ensure the most recent version is available here. This privacy notice was last updated on  July 1 2022

Privacy notice for third parties

owners, directors and representatives of businesses

 

1. Introduction

 

1.1 Allianz Trade and Euler Hermes

Allianz Trade is the trademark used to designate a range of services provided by Euler Hermes group (referred to below as Euler Hermes). Euler Hermes,  member of the Allianz group, is the global leader in trade credit insurance and a recognized specialist in the areas of surety, collections, structured trade credit and political risk. Euler Hermes is present in more than 50 countries with 5,800 employees.

When we process information relating to an individual, such as a sole trader, a partnership or a company director for instance, this is personal data and we process this information in accordance with the applicable laws and regulations. Euler Hermes respects applicable laws and regulations in its use of personal data.

 

1.2 Scope of this privacy notice

This privacy notice applies to information obtained by Euler Hermes when you are, work for or represent a third-party business.

The terms of this privacy notice are subjected to any additional terms, disclaimers or other contractual terms you have entered into with Euler Hermes such as client privacy statements or notices, and any applicable mandatory laws and regulations.

For more information about how we process personal data when you visit this website, or if you are, work for or represent a business that has a contract with Euler Hermes, please click the relevant tab on the left of this page in order to consult the relevant privacy notice. If you are a job candidate, you can consult the relevant privacy notice in the careers section of our website.

As we constantly update this privacy notice, please check it on a regular basis.

 

1.3 Data controller

A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. This privacy notice applies to the following data controllers as defined by relevant data protection laws and regulations:

 

Euler Hermes Consulting (Shanghai) Co., Ltd

05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

2. Which personal data do we process?

 

2.1 Purposes

We process information relating to our customers’ (potential) customers (“buyers”), in order to:

• confirm your business identity;
• support company risk assessment for business, financial and compliance operations;
• establish credit grading profiles;
• provide credit risk information;
• underwrite credit risks for our policy holders;
• issue bonds;
• assess and monitor our own risk;
• collect debts for ourselves and for our customers;
• support the sound management of Euler Hermes and other companies in the Allianz group;
• protect our legal interests, exercise our rights and defend ourselves against legal claims;
• conduct research and analysis with regard to our business operations;
• fulfil our legal obligations, including the respect of the exercise of data protection rights.

 

2.2 Legal basis

This processing is based on the legitimate interests of Euler Hermes, and where relevant of other Allianz group companies and of our customers, to pursue the above mentioned purposes, where such processing is necessary for these purposes.

Before we process any personal data, we balance these legitimate interests with potential impacts on the interests and rights and freedom of the individuals involved.

We make sure to exclude any special categories of personal data from this processing and take into account the reasonable expectations of the individuals involved.

 

2.3 Data categories

We process the following categories of personal data regarding business owners, directors and representatives:

Businesses (mostly commercial entities, but the identity of some businesses are tied up with that of their owner, such as sole traders, partnerships or one-person limited liability companies):

• Business name (which may correspond to a personal name) and legal form;
• Business activity, sector and size;
• Business credit grade;
• Contact data such as: business post address, business email address, business telephone number, business fax number. Wherever possible these data are generic company data rather than personal data (for example, if available we will use info@company.com rather than john.doe@company.com);
• VAT number and other company identification numbers (from governments, chambers of commerce, Euler Hermes, and/or data brokers);
• Financial information related to the business, such as bank domiciliation, bank account, financial status, assets, and net worth;
• Business payment history and patterns, profitability and other information regarding creditworthiness (e.g. payment and risk incidents) including insolvency situation.

Owners, directors and representatives of businesses:

• First name, family name, gender, title, job title;
• Affiliations with different businesses (past & present);
• Shareholder information.
•  

2.4  Information sources

We collect the specified information in accordance all applicable regulations from:

• Yourself;
• Your website or other publications made available by you to the public
• The company that you work for or represent;
• Our customers;
• Our business partners;
• Service providers in the field of abuse prevention (who maintain databases with identification numbers of end devices);
• Service providers in the field of identity verification;
• Direct marketing companies;
• Publicly available information, such as, commercial registers, trade registers, public statistical databases, and websites.

Where we collect your personal data directly from you, there is no obligation to provide us with the personal data we ask for. However, in some cases this may impact the extent to which we can provide you and your business partners with services that facilitate trade.

 

2.5 Retention duration

Your personal data will only be retained by us for as long as is necessary to achieve the above-mentioned purposes, in accordance with our Standard for Information and Document Management.

We will retain your personal data as long as statutory retention requirements exist or any legal claims are possible, for the defence of which the personal data are required.

Payment history data are deleted when it is no longer relevant to the creditworthiness of your business.

It is in the interest of Euler Hermes to only use relevant, correct and up to date information. All the data that we process are updated and checked on an ongoing basis.

 

3. Profiling

Article 4.4 of GDPR, defines ‘Profiling’ as any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Our services activity includes a profiling of businesses to assess credit risk through a grade circulated to our customers that are operating in B2B fields. This profiling may include automatic decision-making.

The Euler Hermes grade is an indication of our assessment of a business’ financial stability according to the available information, and predicts with 12-month probability whether a business is likely to pay invoices on time, receive credit, or whether they are subject to other specific risks.

The Euler Hermes grade may have implications in terms of insurance coverage. Depending on the grade, Euler Hermes customers will be able to benefit from an insurance cover for their credit risks. Our grade does not include any recommendation by Euler Hermes to enter into any contracts or make a delivery. Our customers are provided with appropriate documentation to understand and interpret each level of grade.

In accordance with Article 22 of the GDPR, all sole traders, one-person-companies, businesses’ shareholders, representatives and owners, in so far as they are individuals whose data have been used in the course of Euler Hermes grading activities, can obtain an explanation of the decision reached after such assessments, and they can challenge the outcome by adding to or correcting the information upon which the grade was based, by contacting Euler Hermes at the address indicated in section 1.3.

For the purpose of grading we use different models and algorithms that are constantly monitored and improved. We do not use blacklists and process no special category personal data described in Article 9(1) of the GDPR.

Our grading activity is carried out for the purposes arising from the legitimate interest of Euler Hermes to provide information as well as trade credit insurance services to its customers and more particularly to perform its obligations under the underlying  services contracts and insurance policy. As an insurer, our activity is highly regulated and supervised by competent authorities.

4. Who has access to your personal data?

We ensure that your personal data are processed in a manner that is compatible with the purposes specified above.

For the specified purposes, your personal data may be disclosed to the following parties who operate as third party data controllers:

• Other Allianz group companies;
• Authorized agents, brokers and third party service providers.
• Our customers, if you are their customer or potential customer.

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

• Other Allianz group companies.
• Authorized agents, service providers that facilitate and/or provide parts of our services, and research analysis agencies.
• Facilitators, consultants or experts managing communications and Euler Hermes sponsored events.

Finally, we may share your personal data in the following instances:

• With law enforcement agencies, courts, government and regulatory bodies to meet applicable legal or regulatory obligations, where we are legally obliged to do so.

5. Where will your personal data be processed?

Your personal data may be processed both inside and outside of the European Economic Area (EEA) by the parties specified above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations. We will not disclose your personal data to parties who are not authorized to process them.

Whenever we transfer your personal data for processing outside of the EEA by another Allianz group company, we will do so on the basis of the binding corporate rules (BCRs) of Allianz known as the Allianz Privacy Standard (APS) which establish adequate protection for personal data and are legally binding on Allianz group companies. The public version of the APS and the list of Allianz group companies that comply with them can be accessed here.

Where the Allianz Privacy Standard does not apply, we will instead take steps to ensure that the transfer of your personal data outside of the EEA receives an adequate level of protection as it does in the EEA. You can find out what safeguards we rely upon for such transfers (for example, EU Standard Contractual Clauses) by contacting us as detailed below.

 

6. What are your rights in respect of your personal data?

 

6.1 GDPR rights

Where permitted by applicable law or regulation, you have the right to:

• Access your personal data held about you and to learn the origin of the data, the purposes and means of the processing, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed.
• Withdraw your consent at any time where your personal data is processed with your consent.
• Update and correct your personal data so that it is accurate.
• Delete your personal data from our records if it is no longer needed for the purposes indicated above.
• Restrict the processing of your personal data in certain circumstances, e.g. where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy.
• Object to us processing your personal data, or tell us to stop processing it (including for purposes of direct marketing).
• Obtain your personal data in an electronic format.
• File a complaint with us and/or the relevant data protection authority.

You may exercise these rights by contacting us and providing your name and email address as well as the purpose of your request, using our Data Subject Request form available at:  Data Subject Request form

 

6.2  Residents of California

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. The section below describes these rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Euler Hermes disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, in a portable format:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purposes for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.

Deletion of information

You have the right to request the deletion of your information within the rights provided by the CCPA. The right to deletion does not apply where the retention of personal information is needed to perform any of the following:

• Provide goods or services to you;
• Detect or resolve security or functionality-related issues;
• Comply with the law;
• Conduct research in the public interest;
• Safeguard the right to free speech; or
• Carry out any actions for internal purposes that you might reasonably expect

Non-Discrimination

Euler Hermes will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts, rebates, or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

The Sale of Personal Information

Some personal information that we process as described in section 2 may be shared with other Allianz group companies. This concerns the data categories regarding the identification of you as an entrepreneur and of the businesses you own, represent or work for.

 

7. Protection of your personal data

 

7.1 What security measures protect information?

We have implemented reasonable technical and organizational security measures to protect your personal data against unauthorized access, misuse, loss or destruction.

 

7.2 How do we treat electronic messages sent to and from Euler Hermes?

All electronic messages sent to and from Euler Hermes are protected by reasonable technical and organizational measures and may only be accessed in justified cases in line with applicable laws and regulations (e.g. court order, suspicion of criminal conduct, violation of regulatory obligations) to specific persons in defined functions (e.g. Legal, Compliance, Risk). All emails are disposed of after the applicable retention period has expired.

 

7.3 What should you consider when sending data over the Internet?

The Internet is generally not regarded as a secure environment, and information sent via the Internet (such as to or from the Euler Hermes website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than in your country of residence.

Euler Hermes does not accept responsibility or liability for the security of your information whilst in transit over the Internet to Euler Hermes. In order to protect your privacy you may choose another means of communication with Euler Hermes, where you deem it appropriate.

 

8. How to contact us

If you have any queries about how we use your personal data, no matter the Euler Hermes entity involved, you can contact our Data Protection Officer by post or email via the details specified below:

Post mail:      

Data Protection officer

Euler Hermes Consulting (Shanghai) Co., Ltd

05-07,08A 19F Jin Mao Tower, 88 Century Avenue Pudong New Area, Shanghai, 200120, China

 

Email: privacy.apac@allianz-trade.com

 

9. How often do we update this privacy notice?

We constantly  review this privacy notice and make changes. We will ensure the most recent version is available here. This privacy notice was last updated on July 1 2022