LabTwin Data Privacy Notice

LabTwin Commitment to Data Privacy Protection

Protecting the security and privacy of your personal data is important to LabTwin GmbH, Prenzlauer Allee 242, 110405 Berlin, Germany (“LabTwin”). Therefore LabTwin processes personal data in compliance with applicable laws on data protection and data security. The following policy explains what data our websites and mobile application(each a “LabTwin Online Offering”) may collect and how we deal with your personal data.

TABLE OF CONTENTS

1. Data Controller
2. Processing of personal data related to your use of LabTwin Online Offerings
   • Categories of personal data processed, purpose of the processing and legal basis
   • Cookies
   • App permissions
3. Processing of personal data related to your business relationship with LabTwin
4. Processing of personal data for direct marketing
   • Categories of personal data processed, purpose of the processing and legal basis
   • Data Transfer
   • Withdrawal of your consent
5. Transfer and disclosure of personal data
6. Retention periods
7. Withdrawal of your consent
8. Your rights
9. Children
10. Contact details of our Data Protection Officer
11. Changes to this Data Privacy Notice
12. Sub-processors

1. Data Controller

Responsible for the processing of your data is:

LabTwin GmbH

Prenzlauer Allee 242

110405 Berlin

Germany

Email:   info@LabTwin.com

2. Processing of personal data related to your use of LabTwin Online Offerings
   
   2.1 - Categories of personal data processed, purpose of the processing and legal basis

When visiting a LabTwin Online Offering, LabTwin may process the following personal data about you:

• Information that is automatically sent to us by your web browser or device, such as your IP-address, device type, browser type, referring site, sites accessed during your visit, the date and time of each visitor request;
• Personal data that you voluntarily provide via the LabTwin Online Offering (e.g., when registering, contacting us with your inquiries or participating in surveys, etc.), such as name, e-mail address, telephone number, information submitted as part of a support request, comments or forum posts, etc.; and
• Personal data that you voluntarily may be creating or uploading within files of different formats (voice recordings, images, videos, Excel, Word, pdf, other).

LabTwin processes your personal data for the following purposes:

• To provide, improve, and develop the LabTwin Online Offerings services and functions and to administer your use of these offerings;
• To fulfil your request and improve your experience and our services. When you speak to LabTwin, a voice recording is sent to LabTwin’s cloud, where we process your request and other information. The more you use LabTwin, the more the service adapts to your speech patterns, vocabulary, and personal preferences. Therefore we may use your recordings to train our speech recognition and natural language understanding systems. This process of quality assurance and quality improvement is accompanied by a manual review, where those parts of the voice recordings that have not been reliably recognized by our systems are listened to and transcribed by our specially trained staff, who are bound to confidentiality and cannot associate the recordings with individual users. If you do not wish to provide your voice recordings for this purpose, please send an e-mail to transcription@labtwin.com;
• To create and maintain a trusted and safer environment, such as to verify or authenticate information or identifications provided by you, to conduct security investigations and risk assessments;
• To process your job applications;
• To send you marketing information or to contact you in the context of customer satisfaction surveys;
• To provide, personalize, measure, and improve our advertising and marketing;
• As reasonably necessary to enforce our terms of use, to establish or preserve a legal claim or defense, to prevent fraud or other harmful activities, including attacks on LabTwin’s information technology systems.

The legal basis for LabTwin processing your personal data may be:

• Your Consent to us using the personal details you provide to carry out the purposes we identified to you in accordance with this Notice (Art. 6 (1) (a) GDPR),
• LabTwin exercising its rights and performing its obligations in connection with any contract we make with you (Art. 6 (1) (b) GDPR),
• Compliance with LabTwin’s legal obligations (Art. 6 (1) (c) GDPR), and/or
• Legitimate interests pursued by LabTwin (Art. 6 (1) (f) GDPR). Generally the legitimate interest pursued by LabTwin in relation to our use of your personal data is the efficient operation, management and support of the LabTwin Online Offerings.

2.2 - Cookies

In the context of LabTwin Online Offerings, cookies and tracking mechanisms (“Cookies”) may be used.

On accessing LabTwin Online Offerings the user is notified of the use of cookies and has the opportunity to deselect individual cookies in the banner, except for the session cookies which are required for operation. The default setting for cookies is to accept them. This setting obtains your consent to process the personal data used in this connection before the processing starts. For reasons based on your particular situation, you have the right to object to the processing of your personal data at any time.

You can find further information about the use of cookies by LabTwin in our Cookie Policy.

2.3 - App permissions

To use certain functions of the app you may be required to provide certain App permissions. App permissions allow the App to access information stored on your device.

The App may ask you to grant the following permissions:

• Camera: To enable you to create photos in the app;
• Microphone: To enable you to speak to LabTwin and create voice recordings in the app;
• Photos/Media/Files: To store photos locally on your device;
• Wi-Fi connection: This permission allows the App to access Wi-Fi related information on your device to ensure the error-free transmission of your data, e.g. to repeat sending the data in the event of a lost Internet connection;
• Push notification services: The activation allows LabTwin to provide you with information regarding our product. In the course of using this function and after activation of the push-notification permission, a connection with the push notification service of your operating system provider is established and your device receives notifications over this connection. For this purpose information on your device identifier is transferred to your operating system provider.

You may manage the use of App permissions in the settings of your operating system. Please note that the use of certain functions of the App may not or no longer be possible if you deactivate the respective App permission.

3. Processing of personal data related to your business relationship with LabTwin

In the context of your business relationship with LabTwin, LabTwin may process the following categories of personal data of contact persons at (prospective) customers, suppliers, vendors and partners (each a “Business Partner”): 

• Contact information (such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address); 
• Payment data (such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information); 
• Further information necessarily processed in a project or contractual relationship with LabTwin or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones; 
• Personal data collected from publicly available resources, integrity data bases and credit agencies; and
• If legally required for Business Partner compliance screenings: date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners.

LabTwin may process the personal data for the following purposes:

• Communicating with Business Partners about products, services and projects of LabTwin or Business Partners, e.g. by responding to inquiries or requests or providing you with technical information about purchased products;
• Planning, performing and managing the (contractual) relationship with Business Partners; e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
• Administrating and performing marketing campaigns, market analysis, sweepstakes, contests, or other promotional activities or events;
• Conducting direct marketing activities; 
• Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities; 
• Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and LabTwin policies or industry standards; and
• Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims.

The legal basis for LabTwin processing data about you is that such processing is necessary for the purposes of:

• LabTwin exercising its rights and performing its obligations in connection with any contract LabTwin makes with you (Art. 6 (1) (b) GDPR);
• Compliance with legal obligations of LabTwin (Art. 6 (1) (c) GDPR); and/or
• Legitimate interests pursued by LabTwin (Art. 6 (1) (f) GDPR).  

Generally the legitimate interest pursued by LabTwin in relation to our use of your personal data is the efficient performance or management of our business relationship with you.

In some cases, LabTwin may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for LabTwin processing that data about you may (in addition or instead) be that you have consented (Art. 6 (1) (a) GDPR).

4. Processing of personal data for direct marketing
   
   4.1 - Categories of personal data processed, purpose of the processing and legal basis

Where and as permitted under applicable law, LabTwin may process your contact information for direct marketing purposes concerning LabTwin products and services (e.g. event invitations, newsletters), also by e-mail. This also includes cases where we have received your contact details from third parties (e.g. trade fair organisers or other organisers).

Where consented to receiving LabTwin marketing information on the basis of your personal interests, LabTwin will determine your personal interests by storing information about your visits on LabTwin websites with the help of cookies. These information may include viewed articles, downloaded documents and date and time of access (“Usage Data”) as well as the name of our advertising campaign if you have completed a contact form on a LabTwin website through one of our online advertisements and will be stored in a personal user profile. Information on whether and when you opened a marketing e-mail LabTwin sent to you will also be added to the profile; LabTwin receives this information by calling up small images embedded in the e-mail (known as web beacons).

Moreover, the following information that you provided directly on LabTwin´s Online Offerings or, if applicable, that is stored in LabTwin Customer Relationship Management systems will be added to your profile:

• Personal contact data (e.g. name, title, company, function/role, country, telephone number);
• Information about the company you work for (e.g. address, industry and other publicly available information).

The data described in the preceding paragraph (“Data”) will be used by LabTwin to send you marketing content (e.g. newsletters, invitations to events and trade fairs etc.) concerning products and services that are of interest to you. In addition the Data will be used by LabTwin sales personnel to submit offers to you and to be able to support you / your company in the best possible way.

Your data will be deleted from the marketing automation system of LabTwin if it is no longer needed for marketing purposes or if you have revoked your consent.

4.2 - Data Transfer

LabTwin may transfer your Data for the above-mentioned purposes to other companies of the Sartorius Group. The provider of LabTwin´s marketing automation platform also has the technical ability to access your Data.

4.3 - Withdrawal of your consent

You have the right to revoke your consent at any time with effect for the future, for example by clicking on the corresponding link contained in an e-mail or send us your withdrawal by e-mail.

5. Transfer and disclosure of personal data

For the purposes mentioned above LabTwin may transfer or disclose your personal data to:

• Other companies of the Sartorius Group or third parties in the context of your usage of LabTwin Online Offerings or our business relationship with you;
• third parties which provide IT services to LabTwin and which process such data only for the purpose of such services (e.g., hosting or IT maintenance and support services); and/or
• third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to law enforcement authorities and regulators, to attorneys and consultants).

Sometimes the recipients to whom LabTwin transfers or discloses your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country.

In such cases, if required by applicable law, LabTwin takes measures to implement appropriate and suitable safeguards for the protection of your personal data. Thus, LabTwin transfers personal data to external recipients in third countries only if the recipient has entered into EU Standard Contractual Clauses with LabTwin, implemented Binding Corporate Rules in its organization or – in case of US recipients – the recipient is certified under the Privacy Shield.

6. Retention periods

LabTwin erases your personal data if the retention of that personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or to comply with legal obligations (such as retention obligations under tax or commercial laws).

7. Withdrawal of your consent

In case you declared your consent for the processing of certain personal data by LabTwin, you have the right to withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, LabTwin may only further process the personal data where there is another legal basis for the processing. 

8. Your rights

Under applicable data protection law you may have the right to:

• Obtain confirmation as to whether or not personal data concerning you are being processed, and where that is the case, access to the personal data;
• Obtain the rectification of inaccurate personal data concerning you;
• Obtain the erasure of your personal data;
• Obtain restriction of processing regarding your personal data;
• Data portability concerning personal data, which you actively provided; and
• Object, on grounds relating to your particular situation, to processing of personal data concerning you;
• Withdraw your consent to the processing of your data you have given us with future effect at any time, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal;
• Submit an appeal to a data protection supervisory authority.

9. Children

LabTwin Online Offerings are not directed at children under an age of 16 years.

10. Contact details of our Data Protection Officer

If you have questions about processing of your personal data, you can contact our Data Protection Officer and his team, who are also available for requests for information, applications or complaints:

Sartorius Corporate Administration GmbH

Data Protection Officer

Otto Brenner Straße 20

37079 Göttingen

Germany

Email: datenschutz@LabTwin.com

             dataprotection@LabTwin.com

11. Changes to this Data Privacy Notice

We may update this Data Privacy Notice from time to time to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons.