DIGITAL WORLD – MARCOM SERVICES PRIVACY NOTICE

In the following, we inform you about the processing of your personal data in connection with your registration on our Digital World (“DW”) platform, through which Tech Data GmbH & Co. OHG, Tech Data Österreich GmbH, and Tech Data (Schweiz) GmbH (“Tech Data”) organise live events and virtual events, contests, promotions, surveys, and presentations in the respective countries of Germany, Austria, Switzerland, and Liechtenstein; make videos, white papers, and other materials accessible; and provide platform services (“Marcom Services”).

 

  1. Who is the controller under data protection law?

Tech Data GmbH & Co. OHG, Kistlerhofstraße 75, 81379 Munich (“Tech Data” or “we”) is the data processing controller in connection with your registration on DW and the Marcom Services offered there.

If you are an employee of a Tech Data business partner of either Tech Data Österreich GmbH (Kranichberggasse 6, Europlaza K, 1120 Vienna, Austria) or Tech Data (Schweiz) GmbH (Birkenstrasse 47, 6343 Rotkeuz, Switzerland), and based on the country selection in the profile, your data will also be processed to a certain extent under joint responsibility between us and the respective aforementioned company. In this case, we have defined the respective actual functions and mutual relationships with the respective companies in an agreement; the agreement also describes which of the companies fulfils which data protection obligations.

You can contact our data protection officer for Tech Data GmbH & Co OHG at Tech Data GmbH & Co. OHG, zu Händen des Datenschutzbeauftragten [for the attention of the Data Protection Officer], Kistlerhofstraße 75, 81379 Munich.

 

 

  1. What personal data is processed? On what legal basis?

Unless otherwise expressly described below, the legal basis for the respective processing of your personal data is Art. 6 para. [sic] sentence 1 letter b) GDPR (the performance of the participation agreement concluded with you for the provision of the corresponding Marcom Service(s) and functions).

 

Browser data

As with every visit to a website, your browser transmits the following technical data (“Technical Data”) to us: Date and time of access to one of our websites, your browser type, browser settings, the operating system used, the page you last visited, the amount of data transferred, and the access status (transfer file, file not found, etc.), your IP address, and the device type.

We process this data in order to display the desired content for you, to enable you to use the functions, and to check whether the trade fair platform page is optimally displayed for you.

We use the IP address only for the duration of your visit and store the data for logging purposes only in anonymised form by shortening the IP address so that it can no longer be attributed.

The legal basis for the aforementioned processing of the Technical Data is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest is in being able to display for you the respective accessed Digital World website reliably and as seamlessly as possible).

 

Registration

As part of the registration process, we collect mandatory information that is required for your registration on Digital World; this mandatory information is marked accordingly. You also have the option of uploading your profile picture. This is visible to other participants as part of the chat function.

We use a double opt-in procedure: Your registration is only completed once you have confirmed your registration by clicking on the link in a confirmation email sent to you for this purpose. If this is not done within 2 days, your registration request will be automatically erased from our database.

We process the mandatory information to process your registration and so that we can contact you in the event of queries, set you up as a visitor in the system, and authenticate you at a later visit (through your email address and password). If you wish to upload your profile picture, it will be processed to provide the corresponding profile functions (see below).

We collect your participant category and your country selection and use your registration data to verify the selected category/selection, for example, by comparing it with your domain, customer number (if applicable), and with data already available at Tech Data to ensure that the content authorised for your participant category and relevant for your country is accessible to you.

 

Registration for certain Marcom Services

For some Marcom Services, you need to log in. Depending on the type of Marcom Service, the data to be provided may vary. We process your registration data to organise and implement the selected Marcom Services.

 

Profile function and profile visibility

The provision of the networking functions described in the terms and conditions of participation is an essential part of the strategy of “Digital World” as a virtual industry meeting place. An important part of this is the ability of trade fair visitors to address and communicate directly with each other.

For this to be possible, your name, your company name, and, if provided by you, your profile picture are visible to all other registered DW visitors in attendance.

The purpose of this data processing is to provide and implement profile and networking functions.

 

Chat and other communication features

Insofar as you use the chat or email offered as part of Marcom Service(s), particularly for webinars or other virtual events, we process your name, your email address, sound and image material for the technical processing of the communication (“Communication Data”) to the relevant extent within the scope of the function, the time of the communication, the recipient (one or more visitors and their names), the type and the content of the communication.

We save your chats so that they can be made available to you again. Chats are not end-to-end encrypted and are accessible to our admins. Chats are erased once a quarter.

 

Access to content and links / visits to virtual rooms

Depending on the Marcom Service(s), we present content on technical topics or on products and services of Tech Data or our suppliers or business partners, for example, in the form of webinars or other virtual events, via a download option or in video format, or in the form of virtual presentations via links. If you use these functions, we process your name as well as the date, time, and duration of the access to content or the visit to a webinar or virtual event, the description of the accessed content, and the number of times accessed (“Access Data”).

This data is processed to enable you to use the aforementioned functions, i.e. to enable you to participate in a webinar, for example, or to show a presentation by video.

 

For webinars or virtual events, we use communication or videoconferencing providers such as Zoom, Cisco Webex, Google Meet, and MS Teams to provide our Marcom Service(s). These are US enterprises.

The basis for data processing in connection with these enterprises is Art. 49 para. 1 (b) GDPR (data transfer is necessary for the performance of the participation agreement with you).

 

Participation in contests or similar promotions

If you participate in a contest or similar promotion that we offer, such as a competition for prizes or a giveaway, we process, in addition to your name and the contact details provided by you, the personal data required to verify your eligibility to participate in accordance with the respective terms and conditions of participation in the promotion (for example, your answers to quiz questions, your Marcom Service(s) login and participation, your access to Marcom Service content) and required to determine whether you have won according to the respective conditions.

If this is the case, we will use your contact details to inform you of the award, prize, or giveaway. We will use the address you provided only to send you the award, prize, or giveaway.

The legal basis for this is Art. 6 para. 1 sentence 1 letter b) GDPR (fulfilment of the promotion participation agreement concluded with you).

 

Participation in surveys

If you participate in a survey offered by us, we collect the data requested there for the survey purpose mentioned there, for example, your suggestions for further optimisation of the virtual trade fair. The purpose and data categories required for this vary depending on the survey.

The legal basis is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest is in getting an idea of the subject matter queried in the survey, continuously optimising our trade fair portal and our services, and adapting to customer needs).

 

Use of the “1:1 session function” with manufacturers

If manufacturer links are offered via DW, you can click on them and, from our Digital World websites, access the external websites of the respective manufacturer and their video chat tool or similar tool there.

In this case, you leave Digital World by clicking on the link and are transferred to the external internet presence of the respective manufacturer. We process your “Technical Data” for this purpose.

The legal basis for this is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest is in connecting you with the Internet presence of the manufacturer that you request).

 

Internal CRM assessments, alignment – update of contact data

We use all the aforementioned data categories for our internal assessments, including those of a personal nature, to draw conclusions about the utilisation and success of DW and individual promotions and Marcom Services; to further optimise these as well as future promotions or events; and to determine customer needs and market requirements. We also use your data to update data about you, your company, or your employer in our systems, for example, by updating addresses.

For this purpose, we also access any data that we store about you.

The legal basis for this is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest is in improving the DW platform and our Marcom Services there).

         

Sponsoring/Billing

Some promotions and Marcom service(s) are sponsored by our suppliers. We process your registration data, Access Data, and admission data for the internal preparation of billing with the manufacturers.

The legal basis for this is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest is in correctly preparing manufacturer invoices. In section 7 below, you will see whether we forward data to our manufacturers and, if so, which data.

 

  1. Use of your data for advertising purposes

By us:

Personalised use for advertising purposes. Tech Data will send you marketing offers, newsletters, information about products and services of Tech Data in connection with Digital World, as well as surveys and invitations via email, SMS, telephone calls, and by mail, as well as via banners or chat during your visits to DW. To provide you with relevant and customised information, we process your registration, login, and Access Data for this purpose (with your cookie consent, provided that this information is collected by cookies or similar technologies), combine this data with data already available to us, and analyse it to better understand your professional function and your business preferences.

The legal basis for this processing of your personal data to contact you for advertising purposes in an existing contractual relationship is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, advertising our DW platform and the Marcom Services available there to visitors of DW in a manner geared toward their interests and functions), as well as Section 7 para. 3 UWG [Gesetz gegen den unlauteren Wettbewerb (Act against Unfair Competition)]. For electronic contact by email, or the applicable local arrangement,

 

you can object to the use of your email address for the purposes of personalised advertising in connection with Digital World at any time with effect for the future by sending an email to digitalworld@techdata.com or by using the unsubscribe link in the respective email communication.

 

By third parties:

If you have given your express consent, we forward your personal data (company name, address, business email, telephone, surname, and first name) to suppliers and/or our business partners for the purposes of direct marketing by them. A sensible assignment for you and our partners is sometimes only possible after completion of a Marcom Service(s). In this case, we will provide you with the information upon request after completion of the Marcom Service(s). Otherwise, you will find the information about third parties in the respective consent. Third parties process data in accordance with their privacy notices. The legal basis is Art. 6 para. 1 sentence 1 letter a) GDPR.

 

  1. What data do you need to provide?

Data that must be provided to use DW and/or its functions/promotions:

The mandatory information for successful registration; password and name for logging into DW; login information when logging in for certain promotions; and your name and other participation requirements for contests or competitions for prizes.

With the exception of data that is relevant under tax law in connection with the billing of costs, there is no statutory obligation to provide such data.

 

  1. Your data protection consent

We may ask you for your consent for specific processing within the scope of DW and Marcom Services. If you provide us with this consent, we process your data as described in detail in the consent form.

The granting of consent is voluntary; even without consent or if it is withdrawn, you can continue to register and to visit and use the Digital World functions.

You can withdraw your consent at any time with effect for the future. Withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent up to the time of withdrawal. If you wish to withdraw your consent, please contact digitalworld@techdata.com.

 

  1. Cookies and similar technologies

Which cookies and similar technologies we use and how you can manage them can be found in the information in the appendix to this privacy notice.

 

  1. Who receives your data?

Internal data recipients

Internally, those departments that manage the registrations, promotions, and Marcom Service(s) technically and/or organisationally, as well as the enterprise for which you work, have access to your data.

 

External recipients

  • In the case of manufacturer-financed Marcom Service(s), suppliers have an interest in tracking the success of Marcom Service(s) and of content provided, including for the respective monitoring of success and costs, as well as for the prevention of fraud and corruption.

For this purpose, we will initially transmit to suppliers generally only anonymised data and statistics about the nature and scope of the access to their content, the number of times their content was accessed, and, if required for the supplier for the aforementioned purposes, your company name, company address, job position, and, where applicable, your surname and first name.

The legal basis for transmission is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, the interest of the respective supplier is in implementing success and cost controls with regard to the content and promotions it financed for Marcom Service(s) and in preventing fraud and corruption; our interest is in enabling the supplier to do this so that we can present content from the supplier in the future and in supporting our partners in complying with their legal obligations).

The legal basis for transmitting your name to suppliers based in a country outside the European Economic Area for which there is no adequacy decision of the European Commission is your consent – if granted. This then also includes the data transfer to a country in which the level of data protection does not necessarily correspond to that of the European Union, such as the USA.

 

An overview of the suppliers represented on DW and the countries in which they are based can be found HERE.

 

  • Third parties for marketing purposes. See above: use of your data for advertising purposes

If the supplier is not located in a Member State of the European Economic Area (EEA) or a country that offers an appropriate level of data protection according to the European Commission’s adequacy decision, your consent to transfer for advertising purposes then also includes data transfer to a country in which the level of data protection does not necessarily correspond to that of the European Union, such as the USA.

 

  • Tech Data Companies. Insofar as a Marcom Service(s) is also directed toward participants from countries and particularly business partners of other Tech Data companies, the Tech Data companies named under section 1 have access to your data: Registration data, Access Data, participation in surveys, participation in contests and similar promotions, internal assessments, billings, and use for advertising purposes (subject to compatibility with national requirements for direct marketing).

The legal basis for transmission is Art. 6 para. 1 sentence 1 letter f) GDPR (weighing of interests, our interest and the interest of the receiving company is in developing existing and future customer relationships. The special legal basis for the transmission of personal data to Tech Data (Schweiz) GmbH, if relevant, is Art. 45 para. 1 GDPR (Switzerland is recognised by the EU as a secure third country under data protection law).

 

  • Technical service providers To ensure the technical requirements of our DW, Marcom Service(s) and functions, as well as to communicate with you, we use external technical service providers that we have carefully selected, including other Tech Data companies. Since they may receive access to or process your personal data to some extent when providing their services, we have engaged them for data processing (Art. 28 GDPR). They are strictly bound by our instructions and monitored by us in accordance with the legal requirements.

For the use of US communication and videoconferencing providers, such as Zoom, MS Teams, etc., see above also under the function for access to content / visits to virtual Marcom Service(s).

 

  • Other external data recipients particularly within the framework of contests and similar promotions are third parties who require the data to provide you with services as part of Marcom Service(s), e.g. hotels or travel agencies, organisers, or suppliers.

 

Information about external data recipients to whom we pass on your data for this purpose can also be requested via email at digitalworld@techdata.com.

 

  1. How long will my data be stored?

We store your personal data as long as the participation agreement with you runs in accordance with our terms and conditions of participation. After that, the data will be automatically erased; but in the event of retention periods under commercial or tax law, it will not be erased until after such periods have expired (maximum of 10 years).

We store your data for as long as it is required to provide our DW services and to implement the respective Marcom Service, and then for as long as it is required by law for Tech Data (usually 10 years) or to enforce or defend against legal claims.

Optional information, such as data that we have collected as part of the feedback process or special data in connection with contests (e.g. t-shirt size) will be erased within 3 months after the end of the respective promotion. We store your data for direct marketing until we have received the withdrawal of your consent.

 

  1. What data protection rights do you have?

You have the following rights if the respective legal requirements are met:

Information about our processing of your personal data according to Art. 15 GDPR

Correction and/or completion of data concerning you (Art. 16 GDPR).

Erasure of personal data concerning you if one of the reasons listed in Art. 17 GDPR applies, e.g. if the data is no longer required for the purposes pursued.

Restriction of processing if one of the requirements listed in Art. 18 GDPR is met.

Right to object for reasons arising from your special situation, to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6 para. 1 e) or f) GDPR or for direct marketing purposes (Art. 21 GDPR). We will no longer process your personal data after receipt of your objection unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

Data portability. You have the right to receive from us the data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format. You can also transfer this data to other locations or have it transferred by us.

Withdrawal of consent. If we process your personal data on the basis of consent, you can withdraw this consent from Tech Data at any time with effect for the future, for example, by sending an email to the email address indicated in the declaration of consent. The validity of the data processing on the basis of the consent up to the time of withdrawal remains unaffected.

 

To exercise your rights, please contact: digitalworld@techdata.com.

 

Complaint. You also have the right to complain to a data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection law.

 

  1. Data security

We also use technical and organisational security measures to protect accumulated or collected personal data, particularly against accidental or intentional tampering, loss, destruction, or against the attack of unauthorised persons. Our security measures are continuously being improved based on technological developments.

When using our website, your personal data is encrypted via SSL/TLS technology to prevent access by unauthorised third parties.

 

Appendix to the privacy notice:

Cookies and similar technologies

Use of cookies

Tech Data uses cookies on DW as described in the cookie information on the page.

Cookies are small text files required for the proper functioning of a website or used by websites to make the user experience more efficient. In accordance with statutory requirements, Tech Data may store cookies on your device if they are absolutely necessary for the operation of a Tech Data page. We require your permission for all other cookie categories. In addition, cookies can be either “permanent” cookies or “session” cookies. A permanent cookie consists of a text file that is sent from a web server to a web browser. This text file is saved by the browser and remains effective until its set expiry date. Of course, the user can also erase it before the expiry date. On the other hand, a session cookie expires at the end of the user session when the web browser is closed.

Tech Data uses both absolutely necessary cookies and statistical and marketing cookies. The necessary cookies cannot be turned off, as they are required for the proper functioning of the website, compliance with legal requirements, or for the security of our systems. Statistical cookies help us to understand how visitors interact with our websites by collecting and reporting information anonymously. Marketing cookies are used to better understand visitor behaviour and to optimise our offers accordingly. The intention is to display only those ads that are also really relevant and appealing to the individual user. Statistics and marketing cookies are only set if you actively agree to their use.

You can set your cookie settings in the cookie banner and change them at any time in the footer of the respective Tech Data page under “Cookie Settings”.

For the purpose of optimising our marketing activities, applications from third parties are also used on our websites with your corresponding consent. These are explained in more detail below.

Google Analytics

If you have given your consent, Google Analytics, a web analysis service of Google Ireland Limited (“Google”), is used on this website. Use includes the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across several devices to a pseudonymous user ID, and thus analyse the activities of a user across the various devices.

Google Analytics uses “cookies”, text files that are stored on your computer and enable your use of the website to be analysed. The information generated by the cookie about your use of this website is generally transmitted to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, Google will shorten your IP address beforehand within Member States of the European Union or in other contracting member states of the Agreement on the European Economic Area. Please note that on this website, Google Analytics has been supplemented by IP anonymisation to ensure an anonymised collection of IP addresses (IP masking). The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data of Google. More detailed information on the terms of use and data protection can be found at https://www.google.com/analytics/terms/de.html or at https://policies.google.com/?hl=de.

Purposes of processing
By order of the operator of this website, Google will use this information to assess your use of the website, to compile reports on website activities, and to provide the website operator with additional services related to website use and internet use.

Legal basis
The legal basis for the use of Google Analytics is your consent pursuant to Art. 6 para. 1 sentence 1 letter a GDPR.

Recipients / categories of recipients
The recipient of the collected data is Google.

Duration of data storage
The data sent by us and linked with cookies, usernames (e.g. user ID), or advertising IDs is automatically erased after 14 months. Data whose retention period has been reached is erased automatically once a month.

Rights of data subjects
You can withdraw your consent at any time with effect for the future by preventing the storage of cookies by adjusting the settings of your browser software accordingly; however, please note that, in this case, you may not be able to fully use all functions of this website.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser add-on. Opt-out cookies prevent the future collection of your data when you visit this website. In order to prevent the collection by Universal Analytics across different devices, you must perform the opt-out on all systems used. When you click here, the opt-out cookie is set: deactivate Google Analytics

 

Google Ads

Google Ads is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. With this service, Google and we can detect that an ad displayed by Google was clicked on and that the user was redirected to a page. When you click on the displayed ad, a cookie for conversion tracking is stored on the respective device.
These cookies are only effective to a limited extent, do not contain any personal data, and are therefore not used for personal identification. In this context, Google only creates anonymised user profiles in order to display personalised advertising. Each Google Ads customer receives a different cookie. The ability to track cookies via the websites of Ads customers is thus ruled out. The information obtained by means of the conversion cookie is used to create conversion statistics. In the process, we find out the total number of users who clicked on one of our ads and were redirected to a page marked with a conversion tracking tag. However, we do not receive any information with which we can personally identify users.

You have the option of either changing your cookie settings in the footer of our websites or deactivating cookies directly with the provider at the following URL: https://adssettings.google.com/authenticated

Google Tag Manager

Google Tag Manager is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We use Google Tag Manager to manage various website tags via a browser user interface. Google Tag Manager is a cookieless domain and does not collect any personal data itself. It only triggers other tags that record data in some circumstances. Google Tag Manager does not access this data. No personal data is stored.

LinkedIn Analytics & LinkedIn Insight Tag

We use the conversion tracking technology and the retargeting function of LinkedIn Corporation on our website. LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
With this technology, personalised advertisements on LinkedIn can be displayed to visitors to this website. It also allows for the creation of anonymous reports on the performance of advertisements and information on interaction with the website. For this purpose, the LinkedIn Insight Tag is incorporated into our websites, whereby a connection to the LinkedIn server is established, provided that you visit the respective website and are logged into your LinkedIn account at the same time.
This data is transmitted to LinkedIn and encrypted; the IP addresses are shortened and the direct IDs of the LinkedIn members are removed within seven days to pseudonymise the data. LinkedIn erases this remaining pseudonymised data within 90 days. LinkedIn does not share any personal data with us, but only provides summarised reports on the webpage target group and the performance of the ad.

Further information on data collection and data use as well as the options and rights to protect your privacy can be found in the LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy.

You have the option of either changing your cookie settings in the footer of our websites or deactivating data collection directly on LinkedIn at the following URL: https://www.linkedin.com/psettings/enhanced-advertising.

Twitter Ads

We use the “Twitter pixel” on our websites, a service of Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (hereinafter referred to as: “Twitter”).
With the Twitter pixel, we can track actions of users after they have viewed or clicked on a Twitter advertisement. This method is used to assess the effectiveness of Twitter ads for statistical purposes and for market research purposes and can help us to optimise future advertising measures.
Statistical, pseudonymous data is transmitted to Twitter to provide us with appropriate statistics on this basis and enable us to display offers of interest to you. This data is stored in a cookie. The data collected is anonymous to us – i.e. no conclusions can be drawn about the identity of the users. However, the data is stored and processed by Twitter so that an association with the respective user profile is possible and Twitter can use the data for its own advertising purposes in accordance with the Twitter Privacy Policy: https://twitter.com/privacy. We have no influence on the scope and further use of data collected by Twitter through the use of Twitter pixel.

You can either deactivate the aforementioned collection by Twitter pixel in the footer of our websites under “Cookie Settings” or generally deactivate the use of your data to display Twitter ads directly on Twitter: https://twitter.com/personalization.

Outbrain ads

On our websites, we use the conversion tracking of Outbrain, a service of Outbrain UK Limited, 5 New Bridge Street, London, EC4V 6JAUK (hereinafter “Outbrain”).
With an “Outbrain pixel”, we can track activities of users who have interacted with an Outbrain advertisement. This serves to record the effectiveness of the Outbrain ads, to assess them for marketing purposes, and to optimise them in the future. The advertisements provided by Outbrain are automatically adapted to the interests of the respective user based on the content consumed so far and are “personalised” accordingly.
For this purpose, Outbrain assigns a Universally Unique Identifier (UUID), which can identify users on an end device basis if they visit a website on which the Outbrain widget is implemented. In this process, information on the device source and browser type, as well as an IP address that is completely anonymised by removing the last octet, are also recorded. The data collected is anonymous and does not allow any conclusions to be drawn about the identity of the user.

You have the option of either changing your cookie settings in the footer of our websites or deactivating data collection directly on Outbrain at the following URL: https://my.outbrain.com/recommendations-settings/profile.

 

Social media function

Tech Data provides social media functions that allow you to share your information with your social networks and interact with Tech Data on a variety of social media sites. The use of these functions may result in information about you being collected or shared, depending on the function.

We recommend that you review the privacy policies and settings on the social media sites that you use to interact with us to ensure that you understand what information may be collected, used, and shared by the sites. You can deactivate these functions at any time.

Version date 04/08/2021

 

Maximilian von Mustermann

Corporate Lead for Development

Hewlet Packers International Industries