1 INTRODUCTION
Eurovision Services SA and/or Eurovision Services Madrid S.L. and/or Eurovision Americas Inc., and/or Eurovision EVO PTE., LTD, and/or Eurovision (Beijing) Network Technology CO, LTD, and/or Eurovision Services Middle East - depending on which entity has contracting your services - (acting as Data Controller and hereinafter referred as “ES”, “we”, “our” and “us”) is issuing this Privacy Notice to explain what Personal Data relating to you (being a third party providing us services or to which we provide services or a visitor of our Website) are collected by us, why we are collecting and processing such Personal Data, on which legal basis, and how we will handle your Personal Data.
All processing are done in compliance with the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“Data Protection Legislation”). This Notice represents the minimum standards that we have set with respect to Data Protection Legislation, for ensuring that we collect, use, retain and disclose Personal Data in a fair, transparent and secure way.
Capitalized terms used in this Privacy Notice have the same meaning as those defined by the Data Protection Legislation.
2 LEGAL BASIS
We process your Personal Data for the following purposes and legal basis of the Data Protection Legislation:
- Article 6 (1) (b) – Contract performance: Processing is necessary for the performance of a contract to which the Data Subject is party.
- Article 6 (1) (c) – Legal obligation: Processing is necessary for compliance with a legal obligation to which the Controller is subject.
- Article 6 (1) (f) – Legitimate interests: Processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject.
- Article 6 (1) (a) – Consent: when you voluntarily agree to the use of your name / photo or video for any external communication. When the legal basis of the processing is consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of any processing carried out before the withdrawal of consent (see article 15).
3 CATEGORIES OF PERSONAL DATA COLLECTED
We may process various categories of your Personal Data necessary:
- Identification
- First and last name, position in the company, professional emails, professional phone number, business address, photo.
- National Identifiers
- National ID, passport or other identification documents (which include numbers, photos, place of birth, nationality, etc.), social security numbers, tax identifier, work eligibility such as residency and work pass status.
- Due Diligence
- Business registration verification, insurance certificates, conflict of interest declarations, compliance questionnaires.
- Economic & Financial information
- Bank details, payment historical, financial situation for companies.
- Location
- Place of work, place of residence, geographic location.
- Navigation: cookies and trackers and browsing history.
- Communication: We may collect and store your communication with us, including the information you provided in the communication. This may include the content of emails, video recordings, messages on social media, and the information you add to your account with us.
4 HOW WE COLLECT THE PERSONAL DATA
We collect Personal Data relating to you in 2 ways:
- Directly from you:
- On our Website: You may choose to send us information via email or to enter it on certain pages of this Website and we will collect Navigation data and Identification Data (such as first and last name, work email and password) if you enter your credentials to access restricted parts of our Website as a log-in is required to create a user account. you must provide us with your Identification data.
- For contract performance: Identification data (such as company name, office phone number), Location data, Economic and Financial information data, Communication data, National Identifiers (when applicable) and Due Diligence if we need to ask you more details when performing some compliance checks.
- Other specific types of information may be requested in connection with booking requests, surveys, other promotional offers or other marketing activities, including uploading text, video or audio content.
- Via the Cookies: information about how we use them and what types of information are collected via cookies is described in detail below.
5 SPECIAL CATEGORY OF PERSONAL DATA
We will not collect or process any special category of Personal Data relating to you such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or other beliefs of a similar nature, trade union membership, genetic data, biometric data for uniquely identifying a natural person, health, sex life or sexual orientation.
6 USE OF COOKIES
Cookies are small text files that are placed on your computer or another device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
General information about the cookies used
When you visit our Website for the first time, the entry page will show information on privacy through a “cookie banner” allowing you to manage cookies preferences and provide your consent to the use of specific cookies.
We may also use cookies which are required for technical reasons and for which we do not require your consent. For additional information about specific cookies click on https://www.eurovisionservices.com/about/privacy-notice/cookies.
To set your cookie preferences click on the button “Cookies Preferences”.
7 PURPOSES
We collect and process your Personal Data for the purposes of managing the contractual relationship we have with your company (from the establishment of the relationship until its termination or for a limited time following its termination as may be the case) during the course of its activity. However, no personal data will be processed without a legal ground (or “lawful basis”), as further described in the below table.
7.1 General
| Purpose | Data Category | Legal basis |
|---|---|---|
| Tender: To carry out administrative operations relating to tenders, agreements, orders, receipt of deliveries, invoices, payments, accounting in relation to third parties co-contractors |
|
Article 6(1)(f) - Legitimate interest Conducting tenders and evaluating our potential third parties co-contractor. |
| Processing payments and accounting : prepare payment instruments (invoices, PO) |
|
Article 6(1)(b) - Contract performance |
| Business relation: to enforce our agreements with your company and manage our business relationship |
|
Article 6(1)(b) - Contract performance |
| Compliance: To comply with our legal obligations in terms of our co-contractors’ verifications (due diligence, sanction list, conflicts of interests) |
|
Article 6(1)(f) - Legal obligation Article 6(1)(f) - Legitimate interest |
| External Communication: Marketing: press releases and other external communications and industry news, website, brochures, publications on diverse social media platforms |
|
Article 6(1)(a) - Consent When you voluntarily agree to the use of your name / photo or video for any external communication |
| Audit: To carry out audits and evaluation of co-contractors |
|
Article 6(1)(f) - Legitimate interest To conduct audit and evaluation of our co-contractors to ensure performance of their legal and contractual obligations. |
| Litigation: To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you. |
|
Article 6(1)(f) - Legitimate interest To defend ourselves against any litigations / pre-litigations/ mediations/ etc |
| Merger/ change of control In connection with any business transaction such as a merger, or acquisition of all or part of our business or assets by a third party, or a restructuring, or sale |
|
Article 6(1)(f) - Legitimate interest |
| Request from Official authorities To respond to requests from law enforcement authorities, the courts or other competent authorities |
|
Article 6(1)(f) - Legal obligation |
| Security access control (building/ parking) for visitors |
|
Article 6(1)(f) - Legitimate interest To ensure the security of our premises |
7.2 WEBSITE USE
Cookies are small text files that are placed on your computer or another device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
SUPPORT: to respond to your direct request for Web Support, additional information or resolution of issues related to your account and to conduct related statistics;
SURVEYS and FEEDBACK: to manage your use of the Website, including to the extent applicable, your participation to and/or use of, satisfaction surveys, feedback forms or incident/complaint forms, contests, promotional offers or other online marketing activities;
CUSTOMER CARE: to conduct customer care and market research activities;
MAILING: to send you current mailings or other marketing information, in which we think you would be interested through email, mail or text messaging provided you have given us the explicit permission to do so.
We will not use your Personal Data for any new purposes which are as yet unforeseen in this Privacy Notice, except to comply with a legal obligation. In any event, prior to using Personal Data for other purposes, our Privacy Notice will be updated and we will inform you of the change. For consent-based activities, we will not process your Personal Data for new purposes without first obtaining your consent.
7.3 DIRECT MARKETING
We will not use your Personal Data for direct marketing purposes without your explicit prior consent, except where authorised under applicable law.
If at any time you decide to no longer receive any commercial or promotional information from us, you may, free of charge and without providing any justification, opt-out of any direct marketing campaigns and oppose future processing of your Personal Data for such purposes by sending us an email at legal@eurovisionservices.com and mention “opt-out” in the subject line of your email.
Alternatively, you may use the opt-out procedure provided in any promotional message you receive from us.
Please note that opting out from receiving promotional messages from us will not prevent you from receiving information that relates to any contract you may have entered into with us.
8 NO AUTOMATED DECISION-MAKING
We will not make use of automated decision-making processes, including profiling, except where authorised under applicable law. In such a case, we will inform you of the rationale involved in the decision-making, as well as the significance and the envisaged consequences of such processing for you.
9 SHARING PERSONAL DATA AND TRANSFERRING PERSONAL DATA TO THIRD COUNTRIES
We will not make your Personal Data available to any third party and shall not publicly disclose the Personal Data unless such transfers are based on your specific consent, necessary for the performance of a contract entered into between you and us, or when such transfer of Personal Data is otherwise authorised or compulsory by law or by order of an administration or judicial authority.
We transfer your Personal Data to the following recipients: providers of statistical insights about the use of this Website, mailing tools that help us sending our newsletters and hosting providers and third parties such as providers that need to obtain some information that may contain Personal Data (such as for a synopsis) for the purpose of delivering the services.
Please note that whenever your Personal Data are transferred to processors or third parties located outside the European Economic Area in countries which are not considered by the European Commission to guarantee an adequate level of personal data protection, we will ensure that appropriate measures are implemented according to the Data Protection Legislation and applicable local legislation relating to data protection. You may obtain a copy of the safeguards we have implemented or information as to where your data has been made available by sending us an email at legal@eurovisionservices.com.
10 SHARING ON SOCIAL NETWORKS
We use a social plug-in to enable you to share Website’s information on Social Media platforms of your choice through “Share” buttons.
For data privacy reasons, we deliberately opted against the use of direct social network plug-ins on our Website. Instead, we employ an alternative technical solution that allows you to decide whether to transmit data to the social network operators and when.
Thus, when you visit the Website, Personal Data is never automatically transmitted to a social network. Only when you actively click on the respective button yourself will your web browser connect to the servers of the social network, i.e. clicking on elements and then clicking on the social network’s icon indicates your consent to your browser connecting to the servers of the social network and sending usage data to that social network operator, whether or not you are a subscriber of such social network.
We have no influence over the nature or scope of data that social networks may then gather. For information regarding the purpose and scope of data collection, further processing and use of data by social networks and regarding your data privacy rights and relevant configuration settings, see the social networks’ respective data privacy advisories.
11 LINKS TO THIRD PARTIES WEBSITES
On certain areas of this Website, we may provide links to third parties websites, which are not subject to this Privacy Notice. These links are provided as a convenience to you; however please be aware that we have no control over these third parties or their websites and that they will have a different privacy notice applying to information collected from you when you are on their websites. We encourage you read the privacy notices of all websites carefully before providing personally identifiable information.
12 DATA RETENTION
We retain your Personal Data for the duration strictly necessary for the management of our contractual relationship with you. However, we may archive your Personal Data for longer periods of time: (i) where we are required to do so in accordance with legal, tax and accounting requirements, or (ii) where such data is necessary for litigation or pre-litigation purposes. In such case, your personal data will be archived and retained for the duration imposed by applicable law, or for the duration of the applicable statute of limitations.
13 SECURITY AND CONFIDENTIALITY
We implement appropriate technical and organizational controls and measures to protect your Personal Data, including:
- Encryption and secure communication and storage; and
- Access control and authentication; and
- Employee training on Data Protection & Cybersecurity; and
- Regular system audits and monitoring.
These measures take into account: (i) the state of the art of the technology; (ii) the costs of its implementation; (iii) the nature of the data; and (iv) the risk of the processing.
The purpose thereof is to protect it against accidental or unlawful destruction or alteration, accidental loss, unauthorised disclosure or access and against other unlawful forms of processing.
Moreover, when handling your Personal Data, we:
- only collect and process personal data which is adequate, relevant and not excessive, as required to meet the purposes ; and
- ensure that your Personal Data remains up to date and accurate.
Nevertheless, security requires efforts from all parties involved. We thus encourage you to contribute to these efforts by taking appropriate security measures yourself, including by using strong passwords and keeping all usernames and passwords (if any) confidential.
14 CHILDREN ON THE WEBSITE
This Website is not intended for or directed to children under 16. We do not knowingly collect any information from such individuals. If you believe your child has provided us with Personal Data, please contact us at legal@eurovisionservices.com.
15 YOUR RIGHTS
Under the GDPR, you have the following rights regarding your Personal Data:
- Right of access – to know what Personal Data we hold about you; and
- Right to rectification – to correct inaccurate Personal Data; and
- Right to erasure – in certain circumstances; and
- Right to restriction or objection – to limit certain types of processing.
- Right to portability: we may also provide a copy of any Personal Data that we hold in our records in a format compatible and structured to allow the exercise of right to data portability, to the extent it is relevant under applicable law.
- Lodging a complaint with the Data Privacy competent authority
At any time, you may exercise your right : (i) by clicking here, or (ii) by contacting the Data Protection Officer (DPO) at legal@eurovisionservices.com. You may do so by sending a signed request form with a copy of your ID card, passport or other proof of identity to legal@eurovisionservices.com or by post to the legal department at Eurovision Services SA, 17A L’Ancienne Route, 1218 Grand-Saconnex, Geneva, Switzerland.
Where applicable, you have the right to withdraw consent at any time, this does not affect the lawfulness of Processing based on consent made prior to such withdrawal.
Your request will be treated without undue delay and withing maximum 30 days.
16 DATA PROTECTION OFFICER
We have designated a data protection officer whose contact email address is legal@eurovisionservices.com. You may contact our data protection officer with regard to all issues related to the processing of your Personal Data and to the exercise of your rights under the applicable national and European legislation relating to data protection.
17 EFFECTIVE DATE AND CHANGES
This Privacy Notice is in effect since 25 May 2018. We reserve the right, at our complete discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. We encourage you to check this page periodically to read the most recent version of this Privacy Notice as continued use of this Website after the posting of changes to these terms will mean that you acknowledge these changes.