- INTRODUCTION
The Centurion International AG (“CI”) recognises the importance of privacy and the protection of personal information provided to it and is dedicated to the safeguarding and preservation of such information. Accordingly, CI will take appropriate and reasonable technical and organisational steps to prevent unauthorised access to, or disclosure of your personal information.
This Privacy Policy’s main function is to explain to the user how CI collects, uses and discloses personal information or data when you use our service and the choices you have associated with that data. It contains information regarding the rights of natural and juristic persons to whom personal information relates (“data subjects”).
CI may amend this Privacy Policy and reserves the right to do so, at any stage, without prior notice or consent. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
- HOW TO CONTACT US
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Centurion International AG
Opernplatz 14
60313 Frankfurt am Main, Germany
Tel: +49 69 1532944 42
E-mail: info@centurionlgplus.com
Website: www.centurionlgplus.com
- COLLECTION OF INFORMATION
Data subjects are not required to submit any information to the CI website. However, data subjects may choose to do so by completing our contact forms available on the CI website. In addition, CI collects personal information through one of the following means:
- When a data subject contacts CI or requests information or services;
- CI provides services to data subjects;
- Persons applying for job opportunities at CI;
- Process and respond to requests, enquiries and complaints;
- When persons use CI’s websites or engage with CI through social media; and
- For other purposes and operations which are reasonably related, such as administering, monitoring and improving the CI website, our products, and services.
CI may collect the information directly from a data subject or from third parties.
The interaction with CI on the website will result in the collection of information regarding the person’s activities on the website. Similarly, when anyone engages with CI on any other social media platforms.
When engaging with clients on matters, CI will naturally be exposed to and collect personal information which includes the data subject’s name, contact details, financial information as well as information regarding the matters that the firm assists them with.
As part of its recruitment processes, CI collects information from graduates and employment applicants. This information includes educational information as well as employment history. By enquiring regarding employment opportunities at CI or applying for employment, applicants are deemed to provide their consent to CI’s processing of their personal information for recruitment purposes, which may include screening as well as background and reference checks.
- BASIS AND PURPOSE FOR PROCESSING PERSONAL INFORMATION
CI may process and use personal information:
- To deliver the services the data subject requires, in order to provide and maintain our service;
- For research purposes;
- To notify the data subject about changes to our service;
- To allow the data subject to participate in interactive features of our service;
- To provide customer support;
- To gather analysis or valuable information so that we can improve our service;
- To monitor the usage of our service;
- To detect, prevent and address technical issues;
- To provide the data subject with news, special offers and general information about other goods, services and events which we offer that are similar to those the data subject have already used or enquired about unless the data subject has opted not to receive such information;
- Demographical and statistical information about user behaviour may be collected and used to analyse the popularity and effectiveness of this website. Any disclosure of this information will be in aggregate form and will not identify individual users;
- If the data subject subscribes for data, news, announcements, alerts or any such information to be emailed from the website. The data subject’s details shall be contained on our database until such time the data subject chooses to unsubscribe from this service;
- Marketing and promotion of CI’s services (See further information under No. 10 of this Policy);
- Providing and improving services to clients;
- Improving users’ experience when using CI’s websites;
- Communicating with persons for CI’s internal purposes;
- Enabling CI’s internal operations; and
- Exercising and defending legal rights.
- DISCLOSURE OF PERSONAL INFORMATION
Personal information will not be sold to third parties or provided to direct marketing companies or other such organizations without the data subject’s permission.
CI may release personal information or disclose it to third parties in certain circumstances. These include, but are not limited to:
- Where CI is required or authorised to do so by law or a court order;
- In order for CI to enforce its rights;
- In order for CI to provide services to its clients;
- Third parties who provide research services to CI or its clients;
- Third party service providers to assist us with client insight analytics, such as Google Analytics;
- Government authorities and registries, organs of state, regulators, courts, tribunals and law enforcement agencies.
Please note this list is non-exhaustive and there may be other examples where we need to share personal information with other parties in order to provide the Services as effectively as we can.
- RETENTION OF PERSONAL INFORMATION
CI will retain the data subject’s personal information, content and data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Data to the extent necessary to provide our service, for research purposes, to comply with our legal obligations, to resolve disputes and, to enforce our legal agreements and policies.
- RIGHTS
a) RIGHT OF CONFIRMATION
To the extent granted by the legislator, each data subject shall have the right to obtain from CI the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to execute this right of confirmation, he or she may, at any time, contact CI.
b) RIGHT OF ACCESS AND INFORMATION
To the extent granted by the legislator, each data subject shall have the right to obtain from CI free information about his or her personal data stored at any time and a copy of this information. Furthermore, to the extent granted by the legislator, the data subject shall be given access to the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom the personal data has been or will be disclosed;
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- The existence of the right to request from CI rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- The existence of the right to lodge a complaint with a supervisory authority;
- Where the personal data are not collected from the data subject, any available information as to their source.
Furthermore, data subjects shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact CI.
c) RIGHT OF RECTIFICATION AND DELETION
Each data subject has the right to request that CI corrects, destroys or deletes any of the data subject’s personal information that CI has processed in accordance with this Policy. The personal information that you may request us to correct, destroy or delete is personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or that we are no longer authorised to retain.
d) RIGHT OF WITHDRAW CONSENT
To the extent granted by the legislator, each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact CI.
- USE OF IP ADDRESS
An Internet Protocol (IP) address is a number that is automatically assigned to a computer whenever it is connected to the internet. CI logs IP addresses or the location of computers on the internet. CI collects IP addresses for the purposes of system administration and to audit the use of the website. CI does not link IP addresses to personal information unless it becomes necessary to enforce compliance with the Privacy Policy or to protect our website or its users.
- COOKIES
Our website uses a number of cookies and similar technologies for a number of reasons. We explain these in this Policy, using ‘cookies’ to refer to both cookies and other similar technologies.
- What are cookies?
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies store information regarding website visitors. Cookies are sent to the data subject’s browser from a website and stored on the device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our services provided.
Related terminology:
First and third-party cookies: whether a cookie is “first” or “third” party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user at the time (e.g. cookies placed by www.centurionlgplus.com). Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.
Persistent cookies: these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies: these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
- Your consent
Before we can use some – but not all – of these cookies, we need your consent. Strictly essential cookies do not require your consent. For all other cookies we request your consent before placing them on your device. You can give your consent by continuing to use our website or by clicking on the appropriate button on the pop-up banner displayed to you.
You can manage your consent preferences at any time to accept or reject the use of various categories of cookies, which are not strictly necessary, through our Privacy Preference banner. If you disable cookies and similar technologies, however, some features may not work as intended. If you use your browser settings to block all cookies, which would include blocking our ‘basic performance cookies’, you may not be able to access all or parts of the website.
- Types of cookies that we use
We use essential cookies to operate the core functions of the website. We use certain cookies to give you the best experience that we can as you move around the website and use its features. For example, these cookies allow us to recognise you when you return to our site and enable us to personalise content for you and remember your preferences, such as choice of language or region. These cookies also record your visit to our site, the pages that you have visited and the links that you have followed. We use this information to make our site and information displayed on it more relevant to your interests.
- i) Analytics cookies
Analytics “performance” cookies are used by us for statistical analysis purposes. This helps us to understand how visitors use and move around our website, which inform improvements and adaptations to our website to best meet our visitors’ needs by, for example, making the most popular features the easiest to find and access or ensuring that our site works properly on the devices and technologies our visitors use.
- ii) Marketing cookies
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. They can also be used to allow third parties to display relevant and personalised ads to users through their networks, to measure the effectiveness of advertising campaigns and to limit the number of times you see the same advert.
iii) List of cookies
Listed below is more information about the cookies we use, what they do and how long they remain on your device. ‘Session’ cookies only remain until you close your browser and ‘Persistent’ cookies will have a set end date but that will vary.
Performance:
| NAME | DOMAIN(S) | USE | DURATION |
| _ga,_gat,_gid | Google LLC | Cookie by Google used for website analytics. Generates statistical data on how the visitor uses the website. | 2 years |
Marketing:
| NAME | DOMAIN(S) | USE | DURATION |
| NID | .google.com | Used to unblock Google Maps content. | 6 months |
| NID | google.com | Used to unblock YouTube content. | 6 months |
- MARKETING MATERIALS AND INFORMATION
CI may send marketing and promotional communications and material to data subjects. Please note that we will only provide marketing related information to data subjects when we have a previous contractual relationship or a business relationship with the data subject and provided you do not opt-out to receive those communications. Data subjects do have the right to opt-out at any time. Besides that, data subjects may opt out by clicking on the opt-out link that will be contained in the relevant electronic communication.
- SECURITY OF DATA
To protect the data subject’s personal information, CI takes reasonable precautions and follows industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
- THIRD PARTY SERVICES
In general, the third-party providers utilised by CI will only collect, use and disclose the data subject’s information to the extent necessary to allow them to perform the services they provide to us.
Certain providers may be located in or have facilities that are located in a different jurisdiction than either the data subject or CI. If the data subject elects to proceed with a transaction that involves the services of a third-party service provider, the data subject’s information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
Once the data subjects leave CI’s website or are redirected to a third-party website, the data subject is no longer governed by this Privacy Policy or our website’s Terms and Conditions.
- LINKS TO OTHER SITES
CI’s service may contain links to other sites that are not operated by CI. CI has no control over and assumes no responsibility nor any liability for the content, privacy policies or practices of any third-party website, sites or services.