Privacy Policy

Privacy Policy

Updated March 18th, 2019

OVERVIEW

eWings.com GmbH, Jean-Monnet-Str. 2 10557 Berlin, Germany (referred to as "eWings", "we", "us", and "our") takes its data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use and share personal data in the course of our business activities, including:

  • What personal data we collect and when and why we use it
  • How we share information within eWings and with our service providers, regulators and other third parties
  • Explaining more about cookies
  • Transferring personal data globally
  • How we protect and store personal data
  • Legal rights available to help manage your privacy
  • How you can contact us for more support
  • How you can reach out to our Data Protection Officer

We are firmly committed to protecting and respecting your privacy. We will only hold, process and transfer the personal data that we collect about you and which personally identifies you in accordance with applicable laws, this privacy policy and any terms set out at the point(s) at which personal data is collected (“Collection Terms”). If there is any inconsistency between the Collection Terms and this privacy policy, the Collection Terms will prevail.

This privacy policy applies in relation to data that we collect and process through the website(s) that it appears on. It does not apply to data collection and processing undertaken in connection with any travel services that eWings provides to you or the business you work for, where eWings’s rights and responsibilities are set out in the contract(s) entered for the provision of those services and/or privacy notices provided separately.

You can find out more about eWings, including the address of our office, at www.ewings.com or by contacting us using the information in the ‘contact us’ section.

Changes to our Privacy Policy

We may change this privacy policy from time to time to keep it up to date with legal requirements and the way in which we operate our business. We will post the updated privacy policy on the site so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it so please regularly check these pages for the latest version of this notice.

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.

CONTROLLER OF THE PROCESSING OF YOUR PERSONAL DATA

Controller in the meaning of data protection law is:

eWings.com GmbH

Jean-Monnet-Str. 2

10557 Berlin

Germany

+49/30/5770116-16

service@ewings.com

WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

When we collect information

This privacy policy describes what personal data we collect about you if you:

  • Use our website;
  • Contact us using the using the information in the ‘contact us’ section or fill in any enquiry or other forms on the site.

Personal data we collect and use if you use our websites or online services

We may collect various types of personal data about you, including:

  • Information you provide when you use the ‘contact us’ facility or fill in any enquiry or other forms on the site (for example, your name, email address and telephone number);
  • If you contact us, we may keep a record of that correspondence;

For technical reasons, data such as the following, which your internet browser transmits (so called server log files), is collected: type and version of the browser you use, operating system, webpages that linked you to our site (URL of origin or referrer URL), webpages that you visit, date and time of your visit, your Internet Protocol (IP) address. You must always provide accurate personal data and you agree to update it as necessary in the manner specified below. You also agree that, in the absence of any update, we can assume that the personal data you have provided is correct.

For which purposes we use your personal data and on which legal basis

The legal basis for using your personal data

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. We process your personal data for the following purposes, based on the legal bases listed:

No. Purpose for processing Legal basis for processing Description of legitimate interest for processing if necessary
1 To provide our website Legitimate interest We have a legitimate interest in providing an internet presence, in order to develop and further our business.
2 To contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact Necessary in order to take steps at your request prior to entering into a contract or our legitimate interest We have a legitimate interest in communicating with you upon your request and to deal with any matters arising of that contact.
3 To enable a member of the Hogg Robinson Group of companies and/or the HRG partner network to contact you and provide you with information or services that you have requested and deal with any matters arising as a result of that contact. Necessary in order to take steps at your request prior to entering into a contract or our legitimate interest We and other members of the Hogg Robinson Group of companies and or the HRG partner network have a legitimate interest in communicating with you upon your request and to deal with any matters arising of that contact.
4 To be able to provide you with direct marketing communication regarding the services and products we offer (including by email newsletter) with your consent Consent N/A
5 To be able to provide you with direct marketing communication regarding the services and products we offer by email newsletter without your consent Legitimate Interest We have a legitimate interest in the direct marketing of our services and products as long as this is permitted by applicable data protection law and unfair competition law. See the section "Information on your rights to object" in order to learn how you can object to this use at any time.
6 To determine disruptions and to ensure the security of our systems, including the detection and tracing of (the attempt of) unauthorised access to our web servers Legitimate interest We have a legitimate interest in resolving disruptions, ensuring the security of our systems and the detection and tracing of (the attempt of) unauthorised access.
7 To collect statistical information about the use of our website (so-called web analytics) Legitimate interest We have a legitimate interest in obtaining information about the website use, especially in order to improve our offers.
8 To record and evaluate usage data for interest based advertising. Legitimate interest We and our partners have a legitimate interest in interest based advertising to be able to show our users advertisements based on their personal interests.
9 To safeguard and defend our rights Legitimate interest We have a legitimate interest in exercising and defending our rights.
10 To make disclosures legally required by authorities (e.g. tax authorities, law enforcement and/or our regulatory bodies) Compliance with a legal obligation N/A

If our use of your personal data is in our legitimate interest as a commercial organisation, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the ‘Legal Rights Available To Help Manage Your Privacy’ section below.

If you would like to find out more about the legal basis for which we process personal data please contact us using the information in the ‘contact us’ section.

DISCLOSURE OF PERSONAL DATA WITHIN EWINGS AND TO THIRD PARTIES

We share your information in the manner and for the purposes described below:

  • within members of the Hogg Robinson Group of companies and/or the HRG partner network for the purposes set out in the section above, and otherwise as necessary to provide you with our services or to manage our business;
  • with third parties who manage our business and deliver services. These include data storage providers used in the operation of the site and/or the provision of any of the services provided through it (these providers do not have direct access to the personal data unless specified otherwise on the site);
  • where we are required to do so, with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  • a future purchaser of some or all of our assets or, where applicable, the assets of all or part of the Hogg Robinson Group of companies if and to the extent permitted under applicable laws; and
  • in the unlikely event that we believe in good faith that we are required to do so, in order to protect our rights/property or those of our clients and/or their employees.

TRANSFERRING PERSONAL DATA GLOBALLY

eWings operates on a global basis. Accordingly, your personal data may be transferred and stored in countries outside the EU, including the United States, that are subject to different standards of data protection. eWings will take appropriate steps ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end, where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data are disclosed.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.

DIRECT MARKETING AND USE OF COOKIES

Through this website, we provide you a simple way of choosing whether you wish to receive eWings marketing material that we believe will be of relevance and interest to you. If you agree to receiving eWings marketing material, you are further able to choose how you wish to receive it, i.e. email, text, post etc.

eWings limits direct marketing activities to a reasonable and proportionate level. We ensure you remain in control of your preferences at all times. Each email or text marketing communication will allow you to ‘unsubscribe’ in a few simple steps. Alternatively, you can contact us contacting us using the information in the ‘contact us’ section to unsubscribe from any form of marketing including by phone and/or post etc.

Cookies

Our online offer uses cookies. Cookies are text files that are stored and stored on a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual's browser from other internet browsers that contain other cookies. A particular web browser can be recognized and identified by the unique cookie ID.

Through the use of cookies, the provider can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie the information and offers on our website can be optimized in the sense of the user. Cookies allow us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies need not re-enter their credentials each time they visit the website, as this is done by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently contradict the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

The following third-party cookies are used:

  • Google Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data via this link: https://tools.google.com/dlpage/gaoptout.
  • Intercom: Intercom is provided by Intercom, Inc., 55 Second Street, Suite 400 San Francisco, California, 94105 USA (“Intercom”).

Use of SalesViewer technology

This website uses SalesViewer technology from SalesViewer GmbH on the basis of the website operator’s legitimate interests (Section 6 paragraph 1 lit.f GDPR) in order to collect and save data on marketing, market research and optimisation purposes.

In order to do this, a javascript based code, which serves to capture company-related data and according website usage. The data captured using this technology are encrypted in a non-retrievable one-way function (so-called hashing). The data is immediately pseudonymised and is not used to identify website visitors personally.

The data recording and storage can be repealed at any time with immediate effect for the future, by using the link https://www.salesviewer.com/opt-out in order to prevent SalesViewer from recording your data. In this case, an opt-out cookie for this website is saved on your device. If you delete the cookies in the browser, you will need to use this link again.

WEBSITE ANALYTICS

We require statistical information about the usage of our websites to design them to be user-friendlier and to perform reach measurements and market research. For this purpose, we use the web analysis tools described in this section below. The usage profiles created by these tools using analysis cookies or by evaluating log files are not combined with personal data. The providers of the tools process data only as processors on our behalf and subject to our instructions. The tools either do not collect IP addresses or anonymize these upon collection.

You will find information on each tool's provider and how you are able to object to the collection and processing of data by the tool. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used.

Additionally, you can generally avoid the creation of usage profiles by tracking technologies by generally deactivating cookie usage. For more information on how to do so, please refer to the Cookie section in this document.

  • Google Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data via this link: https://tools.google.com/dlpage/gaoptout.

NEWSLETTER

With the following information we inform you about the content of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

The dispatch of the newsletter and the related performance measurement is based on the consent of the recipient gem. Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission according to Art. § 7 Abs. 3 UWG.

The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves our business interests as well as meeting the expectations of users and allows us to provide proof of consent.

Termination / Revocation - You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

NEWSLETTER ANALYTICS

The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping service provider. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.

This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

ADVERTISING BY MEANS OF TRACKING TECHNOLOGIES

We use so-called tracking tools on this website to better understand your preferences by analysing your behaviour on our website and offer you products or services more in line with your interests (interest-based advertising). The tools either do not collect IP addresses or anonymize these upon collection.

You will find information on each tool's provider and how you are able to object to the collection and processing of data by the tool below. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used.

Additionally, you can generally avoid the creation of usage profiles by tracking technologies by generally deactivating cookie usage. For more information on how to do so, please refer to the Cookie section in this document.

  • AdRoll: AdRoll is provided by AdRoll, Inc., 2300 Harrison Street, Second Floor San Francisco, CA, 94110, United States. You can find further information on this tool here https://www.adroll.com/.

HOW WE PROTECT AND STORE YOUR INFORMATION

Security

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers, destroying or permanently anonymising personal data if it is no longer needed for the purposes for which it was collected and having in place appropriate network and system security measures.

Storing your personal data

We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

We store server log files for a maximum period of 1 month.

In specific circumstances we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us using the information in the ‘contact us’ section. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right of access to personal data

You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data may be transferred.

Right to rectify or erase personal data

You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.

You can also request that we erase your personal data in limited circumstances where:

  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where the data processing was based on consent); or
  • following a successful right to object (see ‘Right to object to the processing of your personal data’ below); or
  • it has been processed unlawfully; or
  • to comply with a legal obligation to which eWings is subject.

We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:

  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims.

Right to restrict the processing of your personal data

You can ask us to restrict your personal data, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where:

  • we have your consent; or
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.

Right to object to the processing of your personal data

You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to direct marketing

Additionally, you may at all times object to the processing of your personal data for direct marketing purposes. Please take into account that, due to logistical reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.

Right to obtain a copy of personal data

You may request that your personal data be transmitted (ported) directly to you a third party, if your personal data was either obtained by consent or is necessary for the performance of a contract and if it is processed by automated means.

Right to withdraw consent

To withdraw your consent to the processing of your personal data at any time, if the processing of your personal data is based on consent.

Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time if you have concerns about how we are processing your personal data.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

OBLIGATION TO PROVIDE PERSONAL DATA

You can also visit our website without disclosing your personal data to us. To be able to make use of some of our services (for example if you would like to get in touch with us) you are, however, obliged to provide us with the personal data needed for the particular service (for example the name, address, e-mail address); we mark these mandatory details with an asterisk *. If you decide not to provide us with this information, you will unfortunately not be able to use these services.

SOCIAL LOGIN

When registering or logging in to eWings.com, you can either enter your e-mail address and set a password or you can select your account on either Google, LinkedIn, Xing or Facebook. When you choose the second option, you will allow eWings.com to use selected data of your profile from these providers. Only the data required for registration at eWings.com will be transferred.

CANDIDATE PRIVACY POLICY

We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfil our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO, if the data processing is e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).

The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form, marked, otherwise result from the job descriptions and basically include the details of the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this Privacy Policy.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).

If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.

Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.

The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.

The cancellation is subject to a legitimate cancellation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.

CONTACT US OR OUR DATA PROTECTION OFFICER

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the site’s ‘Imprint’ information. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

Alternatively you may reach us at:

eWings.com GmbH, Jean-Monnet-Str. 2 10557 Berlin, Germany

service@ewings.com

Fax: +49/30/5770116-20

Tel: +49/30/5770116-16

Ron Littmann, Jean-Monnet-Str. 2, 10557 Berlin, Germany, ron.littmann@ewings.com

eWings.com GmbH
Jean-Monnet-Str. 2
10557 Berlin

T +49 30 577 01 16 18
F +49 30 577 01 16 20
service@ewings.com

Registergericht Berlin Charlottenburg
HRB 153136 B

Umsatzsteuernummer: DE291653034
Geschäftsführer: Thilo Hardt, William Francis Brindle