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Privacy Policy (4th September 2023)

With the following information we would like to inform you about the processing of your personal data by us and your rights resulting from the data protection laws and especially from the general data protection regulation (regulation (EU) 2016/679 - "GDPR").

In the first part of this privacy policy (chapters 1 to 6), we provide you with general information about data protection. In the second part (chapter 7), you will find detailed information about data processing in the more concrete context of the Workplace Pure platform.

Controller and data protection officer
1. Controller in accordance with Art. 4 VII GDPR is:
  Most data processing will take place through Konica Minolta’s Customers, which generally is your employer. The information on the Controller will be given by the company responsible for giving access to the Workplace Pure Cloud Platform.
  
  For clarification: Konica Minolta is considered a Processor (acc. Article 28 GDPR), the processing between the Controller and Konica Minolta on the use of the portal is covered by internal contracts on data protection between the Controller and Konica Minolta. These data processing agreements that describe processing on behalf have been concluded between the controller and Konica Minolta. Processing activities carried out by Konica Minolta Business Solutions Europe GmbH as a controller are explicitly indicated.
2. Konica Minolta’s data protection officer
  You may also contact Konica Minolta’s data protection officer if you have any questions relating to the topic of data protection:
  
  Dr. Frederike Rehker
  Konica Minolta Business Solutions Europe GmbH
  Europaallee 17, 30855 Langenhagen (Germany)
  Tel.: +49 (0)511 7404-0
  Email: dataprotection@konicaminolta.eu
What are my rights as a data subject?
As a data subject, you have the following rights:
1. Right of access (Art. 15 GDPR)
  You have the right to be informed at any time of the categories of personal data processed, the purposes of processing, any recipients or categories of recipients of your personal data and the planned storage period.
2. Right of rectification (Art. 16 GDPR)
  You have the right to request the rectification or completion of personal data concerning you that is incorrect or incomplete.
3. Right to erasure („right to be forgotten “) (Art. 17 GDPR)
  You have the right to request the immediate erasure of your personal data. In particular, we are obliged as the controller to delete your data in the following cases:
  - Your personal data is no longer needed for the purposes for which it was collected.
  - A processing of your personal data took place solely on the basis of your consent, which you have now withdrawn, and there is no other legal basis that legitimises a processing of your personal data.
  - You have objected to a processing which is based on the legitimate or public interest and we cannot prove that there are legitimate grounds for processing.
  - Your personal data has been processed unlawfully.
  - The erasure of your personal data is necessary in order to comply with a legal obligation to which we are subject.
  - Your personal data has been collected in connection with information society services offered in accordance with Art. 8 I GDPR.
  Please be aware that the right to erasure is subject to a limitation in the following cases, so that a deletion is excluded:
  - Your personal data is used to exercise the right to freedom of expression and information.
  - Your personal data serves to fulfil a legal obligation to which we are subject.
  - Your personal data is used to carry out a task that is in the public interest or in the exercise of official authority that has been assigned to us.
  - Your personal data serves the public interest in the field of public health.
  - Your personal data are necessary for archiving purposes in the public interest, for scientific or historical research or for statistical purposes.
  - Your personal data serve for us to establish, exercise or defend legal claims.
4. Right of restriction of processing (Art. 18 GDPR)
  You also have the right to request that the processing of your personal data be restricted; in such a case, your personal data will be excluded from any processing. This right applies if:
  - You contest the accuracy of your personal data and we have to verify the accuracy of your personal data.
  - The processing of your personal data is unlawful and instead of erasing your personal data, you request a restriction of processing.
  - We no longer need your personal data for the fulfilment of the specific purposes, but you still need this personal data to establish, exercise or defend legal claims.
  - You object to the processing of your personal data and it has not yet been determined whether your or our legitimate reasons override this.
5. Right of data portability (Art. 20 GDPR)
  You have the right to receive the personal data concerning you that you have provided to us as a controller in a structured, common and machine-readable format and to transfer it to another controller. Furthermore, you also have the right to request that your personal data be transferred from us to another controller, insofar as this is technically feasible.
  
  The requirements for the applicability of data portability are:
  - Your personal data is automatically processed based on your consent or a contract.
  - Your personal data does not serve to fulfil a legal obligation to which we are subject.
  - Your personal data will not be used to perform a task that is in the public interest.
  - Your personal data do not serve for the performance of a task which is performed in the exercise of a official authority delegated to us.
  - The exercise of your right shall not interfere with the rights and freedoms of others.
6. Right to object (Art. 21 GDPR)
  You have the right at any time to object to the processing of your personal data on grounds arising from your particular situation. This also applies to profiling. The requirement for this is that the processing is based on a legitimate interest on our part (Art. 6 I 1 lit. f GDPR) or the public interest (Art. 6 I 1 lit. e GDPR).
  
  Furthermore, you may also at any time object to the processing of your personal data for the purposes of direct marketing or profiling linked to such direct marketing.
  
  Should you object to the processing of your personal data based on a legitimate interest, we will check in each individual case whether we can show grounds worthy of protection that override your interests and rights and freedoms. In the event that there are no reasons worthy of protection on our part or your interests as well as rights and freedoms override our own, your personal data will no longer be processed. An exception is made if your personal data is still used for the establishment, exercise or defence of legal claims.
  
  If you object to the processing of your personal data for the purposes of direct marketing or profiling, insofar as this is linked to such direct marketing, your personal data will no longer be processed for these purposes.
7. Right to lodge a complaint with the supervisory authority (Art. 77 GDPR)
  You also have the right to lodge a complaint with a supervisory authority at any time, in particular with a supervisory authority in the Member State of your residence, place of work or place of suspected infringement, if you consider that the processing of personal data concerning you is in breach of the data protection regulations.
  
  The address of the supervisory authority responsible for our company is:
  
  Barbara Thiel
  Die Landesbeauftragte für den Datenschutz Niedersachsen
  (State Commisioner for Data Protection of Lower Saxony, Germany)
  Prinzenstraße 5
  30159 Hannover (Germany)
  Telefon +49 (0) 511-120 4500
  Fax +49 (0) 511-120 4599
  poststelle@lfd.niedersachsen.de
8. Right of withdrawal (Art. 7 GDPR)
  If you have given us consent to process your personal data, you can withdraw this consent at any time without giving reasons and in an informal manner. Withdrawal of consent does not affect the lawfulness of the processing that has taken place on the basis of the consent up to the point of withdrawal.
General information regarding the topic „purposes“
As a matter of principle, the processing of your personal data by us is always linked to a specified, explicit and legitimate purpose, which has already been defined before the processing activity is commenced, in accordance with the principle of purpose limitation under Art. 5 I lit. b GDPR. In the further course of this privacy policy, when a processing activity is cited, a description of the specific purpose is also included.
General information regarding the topic „legal bases“
We process your personal data in accordance with the GDPR. Accordingly, the processing of your personal data is always founded on a legal basis. Article 6 of the GDPR defines legal bases for the processing of personal data.
1. Legal bases for the processing of personal data
  Consent
  
  If we obtain your consent for the processing of your personal data, the processing will be carried out on the legal basis of Art. 6 I 1 lit. a GDPR. The following example serves to clarify this legal basis: You receive advertising from us by electronic mail and/or telephone and have given your prior consent.
  
  Contract or pre-contractual measure
  
  If the processing of your personal data is necessary for the fulfilment of a contract with you or for the implementation of pre-contractual measures taken in response to your request, the legal basis on which the processing of your personal data is based is Art. 6 I 1 lit. b GDPR.
  
  Legal obligation
  
  In cases where the processing of your personal data is necessary to comply with a legal obligation to which we are subject, this processing is based on Art. 6 I 1 lit. c GDPR.
  
  Vital interest
  
  Should the processing of your personal data be necessary to protect your vital interests or those of another person, this processing is carried out in accordance with Art. 6 I 1 lit. d GDPR.
  
  Public interest
  
  In cases where we process your personal data in order to perform a task which is in the public interest or in the exercise of official authority delegated to us, Art. 6 I 1 lit. e GDPR constitutes the legal basis.
  
  Legitimate interest
  
  If the processing of personal data is necessary to safeguard a legitimate interest of our company or a third party and at the same time the interests, basic rights and fundamental freedoms of the data subject, which require the protection of personal data, do not override our legitimate interest, Art. 6 I 1 lit. f GDPR serves as the legal basis for the processing.
2. Legal bases for the processing of special categories of personal data
  If, in extraordinary cases, we need to process special categories of personal data, such as
  - data on racial or ethnic origin (e.g. skin color or special languages),
  - data on political opinions (e.g. party memberships),
  - data on religious or philosophical beliefs (e.g. membership of a sect),
  - data on trade union membership,
  - genetic data,
  - biometric data (e.g. fingerprints or photographs),
  - health data (e.g. identification numbers for disabilities),
  - or data concerning the sex life or sexual orientation
  by you, this processing is based on one of the following legal bases, which are defined in Article 9 GDPR:
  
  Explicit consent
  
  If you have given us your explicit consent for the processing of the above categories of personal data, this constitutes the legal basis for the processing in accordance with Art. 9 II lit. a GDPR.
  
  Performing duties under social security/protection and employment law
  
  If the processing of special categories of personal data relating to you is necessary in order to comply with a legal obligation arising from social security/protection or employment law, the legal basis for this processing is Art. 9 II lit. b GDPR.
  
  Protection of vital interests
  
  If the processing of special categories of personal data relating to you should be necessary to protect your vital interests or those of another person, such processing is carried out pursuant to Art. 9 II lit. c GDPR.
  
  Manifestly public data
  
  Insofar as special categories of personal data of yours are processed, which have previously been made public by yourself, the processing of these data is based on Art. 9 II lit. e GDPR.
  
  Establishment / Exercise / Defence of legal claims
  
  Insofar as the processing of the special categories of personal data relating to you serves us to establish, exercise or defend legal claims, Art. 9 II lit. f GDPR constitutes the legal basis for the processing.
  
  Substantial public interest
  
  In the case of the processing of special categories of personal data concerning you in order to safeguard a substantial public interest arising from EU or national law, the processing is based on Art. 9 II lit. g GDPR.
  
  Assessment of the person's work capacity or other medical purposes such as health care
  
  If the processing of special categories of personal data relating to you arises from a law of the EU or a Member State or a contract concluded with a member of a health profession and is carried out for the purposes of preventive health care, occupational medicine, assessment of an employee's work capacity, medical diagnosis, care or treatment in the health or social field or the management of systems and services in the health or social field, this processing is based on Art. 9 II lit. h GDPR.
  
  Public interest in the area of public health
  
  If the processing of special categories of personal data of yours should be necessary for public health reasons, including protection against cross-border health threats such as pandemics, this processing is carried out on the legal basis of Art. 9 II lit. i GDPR.
  
  Archival purposes, scientific / historical research purposes, statistical purposes
  
  Should the processing of special categories of personal data relating to you arise from a right of the EU or a member state, which stipulates processing for archiving, scientific or historical research or statistical purposes in the public interest, this processing is based on Art. 9 II lit. j GDPR.
General information regarding the topic „obligation to preserve records and time limits of erasure
Unless otherwise stated, we delete personal data in accordance with Art. 17 GDPR or restrict its processing in accordance with Art. 18 GDPR. Apart from the retention periods stated in this privacy policy, we process and store your personal data only as long as the data are necessary for the fulfilment of our contractual and legal obligations. Personal data that are no longer required after the purpose has been fulfilled will be regularly deleted, unless further processing is required for a limited period of time, which may result from other legally permissible purposes. In order to fulfil documentation obligations as well as to comply with statutory obligations to preserve records in Germany, the necessary documents are kept for six years in accordance with § 257 I Commercial Code (HGB) and for ten years in accordance with § 147 I of the Fiscal Code of Germany (AO).
General information regarding the topic „disclosure of personal data
Recipient of your data

We do not sell or rent user data in principle. A transfer to third parties beyond the scope described in this privacy policy will only take place if this is necessary for the processing of the respective requested service. For this purpose, we work together with service providers in the areas of marketing, sales, IT, logistics and human resources, among others. We select these service providers extremely carefully. In other cases we transfer data to requesting governmental authorities. However, this only takes place if there is a legal obligation to do so, for example if a court order exists.

Locations of the processing of your personal data

In principle, we process your data in Germany and in other European countries (EU/EEA). If your data is processed in countries outside the European Union or the European Economic Area (i.e. in so-called third countries), this will only take place if you have expressly consented to it, if it is stipulated by law or if it is necessary for our service provision to you. If, in these exceptional cases, we process data in third countries, this will be done by ensuring that certain measures are taken (i.e. on the basis of an adequacy decision by the EU Commission or by presenting suitable guarantees in accordance with Art. 44ff. GDPR).
Workplace Pure: In the context of which processing activities are my personal data processed?
1. Processing activity – Visiting of our website
  Insofar as you use our website solely for informational purposes, i.e. if you do not register in the platform or otherwise transmit information to us, we only collect the personal data that your personal browser transmits to our server. The Workplace Pure platform is hosted GDPR compliant with Open Telekom Cloud (a company of the Telekom Systems International GmbH) servers in Germany and the Netherlands. This data is technically necessary so that the website can be displayed to you. Furthermore, this data is technically necessary to ensure the stability and security of our website. The legal basis for the processing of your personal data in this case is Art. 6 I lit. f GDPR; the legitimate interest in this case is the provision and optimal presentation of this website as well as the protection of this against external attacks and their traceability. We delete this personal data after the end of the usage process, unless we need it for purposes of abuse detection and abuse traceability; in such a case, we retain this data for up to a maximum of 30 days.
  
  When visiting our Workplace Pure website landing page, the following personal data may thus be processed, which is automatically transmitted by your browser to our servers and stored there in the form of so-called “log files”:
  - IP address of the terminal device used to access the website
  - Date, time and duration of the request
  - Country of origin of the request
  - Content of the request (specific page / file)
  - Access status/http status code (e.g. “200 OK”)
  - Internet address of the website from which the request to access our website was made
  - Browser and installed add-ons (e.g. Flash Player)
  - Operating system and interface
  - Language and version of the browser software
  - Amount of data transferred in each case
  - Time zone difference to Greenwich Mean Time (GMT)
  We can only provide some of the services offered on our website landing page if we are able to contact you. In this respect, the possibility of using these services depends on you providing us with certain personal (contact) data. We collect, use and process this personal data only to the extent necessary to provide you with the respective service. If you contact us by e-mail or via a contact form, the personal data you provide in each case (your e-mail address and other information you provide voluntarily, such as your name/telephone number) will be stored by us in order to process your request and, if necessary, answer your questions.
  
  Here, the legal basis for the processing of your personal data is Art. 6 I 1 lit. f GDPR; the legitimate interest is to answer your request. After a final response to your request, we delete your request and the information on the processing with a period of three years after the end of the respective calendar year.
2. Processing activity – General information on Workplace Pure Cloud Platform
  Konica Minolta is offering the Workplace Pure platform to its customers and is acting as a data processor on behalf. Customers planning to transmit personal data into the Workplace Pure Cloud platform services should sign the Data Processing Agreement available in the registration page of the platform.
  
  How personal data is processed at user level in the various services offered through the platform is determined by the customer, which generally is your employer. Nevertheless, we would like to inform the users about how Konica Minolta process data through this platform.
  
  For detailed information you should contact your employer/Workplace Pure administrator.
  
  Our customers need to register before they can use the Workplace Pure platform. The person who registers to the platform must be entitled by their company to order our services. The person that registers their company on our platform takes over an administrator role for their company.
  
  During registration – and in addition to company data – the contact details of the administrator and optionally of another general contact person, will be collected, as follows:
  - Customer data – company name, address suffix, street, ZIP Code, city, country, billing address, if applicable Konica Minolta customer number, if applicable associated trade partner (indirect distribution), if applicable trading partner number (indirect distribution).
  The following customer administrator personal data, (normal) user, helpdesk staff, and Konica Minolta administrator data are also processed:
  - Salutation, first name, last name, phone, mobile, fax, e-mail address, IP address. Personal data of users are anonymised through SQL queries.
  After successful registration to Workplace Pure, the administrator is enabled to register further Users to the platform. Names, email addresses and pseudonyms are needed for this. At this point, all further data processing must be governed by the employer data privacy policy.
3. Processing activity – Operation and Use
  The authorisation concept provides three different user roles. The super administrator, administrator and user. Super administrators and administrators are in charge to create new users and sign up the company for services and assign these to users at the Workplace Pure platform. Super administrators can be assigned for group-wide management of the Workplace Pure services, while administrators act at an individual company level.
  
  What kind of personal data are processed depends on the services in use. All connections between terminals and the Workplace Pure cloud – as well as all connections between Workplace Pure and connected cloud service providers and/or storage providers – are encrypted. Within the use of the Workplace Pure cloud platform services, Konica Minolta is the provider of the services and not the data controller. Customers planning to transmit personal data into the Workplace Pure Cloud platform services should sign the Data Processing Agreement available in the registration page of the platform.
  
  Specific information regarding the data processing within the separate Workplace Pure modules are available for the controller/the administrators in the Workplace Pure store where the services can be ordered.
  
  For billing reasons, the use of the individual services is consolidated and processed at client level, but never at user level. In rare cases of 3rd level support for the Workplace Pure cloud platform, Konica Minolta might involve external software developers.
Konica Minolta Global Policy
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