Which Personal Data is collected?
Grundfos (Singapore) Pte. Ltd. and Grundfos Holding A/S (“Grundfos”, “our”, “we”, “us”) has collected contact information about you and collects and processes further contact information that you choose to provide when responding to surveys from Grundfos. Such information may include email, name and telephone number from you and/or your company (hereinafter the “Personal Data”). Furthermore, Grundfos collects and processes your survey answers which may also contain Personal Data.
Grundfos operates with two different kinds of surveys:
Online survey on Grundfos’ website
Grundfos collects and processes the contact information you choose to provide when responding to online surveys on Grundfos’ website. Such information may include email and telephone number from you and/or your company, your experience in dealing with Grundfos and/or any other personal data you may provide us (hereinafter the “Personal Data”). Furthermore, Grundfos collects and processes your survey answers which may also contain Personal Data.
The provision of Personal Data in connection with online surveys is voluntary. If you choose to be anonymous and not provide Personal Data when responding to online surveys from Grundfos, no Personal Data will be stored or processed. You are free to decide whether you want to provide your Personal Data to Grundfos. However, you are obliged to provide the Personal Data if you want to be contacted by Grundfos regarding your survey answers and receive quick support from Grundfos.
Email invitation
If you respond to a survey following an email invitation, Grundfos already has collected your contact data. Your survey answers which may contain additional Personal Data will also be collected and processed by Grundfos.
You are free to decide whether you want to participate in the survey and provide answers to Grundfos.
The Purposes of collecting, using or disclosing Personal Data
Grundfos may/will collect, use and/or disclose the Personal Data for the purposes of:
(a) dealing with, administering, sending out and conducting customer surveys and/or your responses to the surveys, with the aim of developing the business in accordance with customer needs;
(b) dealing with, managing and/or reacting quickly to specific customer needs and/or to provide quick support;
(c) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(d) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;
(e) creating reports with respect to the surveys and/or your responses to the surveys;
(f) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Grundfos and/or of its affiliates/related corporations. (collectively the “Purposes”)
When you have completed the survey, your input to the survey and Personal Data may be used by Grundfos to reach out to you to improve your experience with the service. Grundfos may/will need to disclose your Personal Data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your Personal Data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your Personal Data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes.
Without limiting the generality of the foregoing, such third parties include:
(i) our associated or affiliated organisations or related corporations;
(ii) any of our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data
centres; and
(iii) third parties to whom disclosure by Grundfos is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.
The legal basis for collecting, using or disclosing Personal Data Grundfos is processing your Personal Data on the basis of your consent pursuant to Singapore’s Personal Data Protection Act (“PDPA”), unless an exception to the requirement of consent under the PDPA applies.
To the extent that the European General Data Protection Regulation (Regulation (EU) 2016/679)) is applicable to the activity in question and to our processing of your personal data, do note then that the processing of Personal Data is necessary in order to fulfil or protect the legitimate interest of Grundfos. Grundfos has deemed that this interest overrides any interests or fundamental rights and freedoms the customer completing the survey may have which require the protection of personal data (Article 6, para. 1, lit. f of the General Data Protection Regulation (Regulation (EU) 2016/679)). The legitimate interest and objective of Grundfos is to develop its business in accordance with customer needs and to provide quick support, thus being able to deliver the best possible customer experience. That objective and interest is deemed not to be overridden by interests or fundamental rights and freedoms of the customer completing a survey. Special regard is given to the fact that the customer may decline an invitation to participate in a survey, and the fact that the survey is ultimately also in the interest of the customer whose data are being processed, because the survey is used to improve customer experience.
Your Personal Data may only be processed for different purposes if the processing is otherwise lawful under applicable law. If we intend to process your Personal Data for a different purpose, we will obtain your consent before doing so, unless an exception to the requirement of consent under applicable law applies.
Where is the Personal Data stored?
Your Personal Data are stored on a Qualtrics server controlled solely by Grundfos’ affiliate or related corporation and placed in Ireland and in Grundfos’ affiliate or related corporation’s Microsoft Azure data lake environment placed in Ireland.
Details of the data controller and recipients of the Personal Data
Grundfos (Singapore) Pte. Ltd. and Grundfos Holding A/S, Poul Due Jensens Vej 7, 8850 Bjerringbro, Denmark, email ecss@grundfos.com are joint data controllers and responsible for data security and the processing of your Personal Data according to the specific Purposes mentioned above.
Grundfos can share your Personal Data with third parties acting as Grundfos’ or Grundfos’ affiliate’s data processors/data intermediaries for processing your Personal Data according to the Purposes mentioned above. The following data processors/data intermediaries are used:
· Microsoft Ireland Operations Limited, Atrium Building Block B, Carmenhall Road, Sandyford Industrial Estate, Dublin 18, Ireland: Microsoft provides IT infrastructure.
· SAP DANMARK A/S, Lautrupsgade 11, 2100 København Ø, Denmark: SAP
assists Grundfos in the processing of customer data and provides the system for the processing.
· Other local companies within the Grundfos Group that will assist with IT support for the above systems.
· Other recipients, typically consultants, that will assist with IT support for the above systems and assist with the processing of your Personal Data on behalf of Grundfos in the above systems.
Other authorised third parties may need to access or store Personal Data if required or permitted by applicable law (e.g. governmental authorities, courts, external advisers and similar third parties that are public bodies).
Transfer of the Personal Data
In certain cases, your Personal Data may be transferred outside of your country. Grundfos ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of your country which comes into possession of your Personal Data must ensure an adequate level of protection, for example by entering into a suitable data transfer agreement. If you have any inquiries in relation hereto, you are welcome to contact Grundfos – please see the contact information below in the ‘How can you access your Personal Data?/Further rights’ section.
Retention period
Your Personal Data will only be stored as long as necessary to fulfil the above-mentioned Purposes, and only if you are in a business relationship with Grundfos. Some of your Personal Data may be stored for a longer period in an anonymised form that does not allow you to be identified. If you are not in a business relationship with Grundfos, your Personal Data will either be deleted or anonymised 6 months after you have completed a survey, unless you have entered into a business relationship with Grundfos by that time. In any case, we will retain your Personal Data in accordance with the requirements of the PDPA.
Some of your Personal Data may, however, be stored for accounting purposes or for defence of legal claims. This Personal Data will be stored until the expiration of the statutory limitation period.
How can you access your Personal Data?/Further rights
Under applicable law, you have various rights (under the conditions set out in applicable law).
Right of access: You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is processed, and, where that is the case, to request access to this Personal Data. The access to information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data has been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the Personal Data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectification: You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. Right to erasure ("right to be forgotten"): Under the General Data Protection Regulation (Regulation (EU) 2016/679))(“GDPR”), you may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data. Do note however that this right is only extended to Personal Data of individuals where the GDPR applies. If only the PDPA applies to your Personal Data, then you have no such right.
Right to restriction of processing: Under the General Data Protection Regulation (Regulation (EU) 2016/679)), you may have the right to obtain from us restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes. Do note however that this right is only extended to Personal Data of individuals where the GDPR applies. If only the PDPA applies to your Personal Data, then you have no such right.
Right to object: Under the General Data Protection Regulation (Regulation (EU) 2016/679)), you may have the right to object the processing of your personal data by Grundfos, on grounds relating to your particular situation, at any time. Grundfos may be required to cease processing your personal data. Do note however that
this right is only extended to Personal Data of individuals where the GDPR applies. If only the PDPA applies to your Personal Data, then you have no such
right.
Right to data portability: Under the General Data Protection Regulation (Regulation (EU) 2016/679)), you may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity without hindrance from us. Do note however that this right is only extended to Personal Data of individuals where the GDPR applies. If only the PDPA applies to your Personal Data, then you have no such right.
If you would like to know more or wish to exercise one or more of the rights listed above, you are welcome to contact Grundfos (Singapore) Pte. Ltd. or Grundfos Holding A/S by sending an e-mail to ecss@grundfos.com or to contact Grundfos (Singapore) Pte. Ltd.’s Data Protection Officer at: dpo@grundfos.com
Filing of complaints
In case of complaints, you also have the right to lodge a complaint with the Personal Data Protection Commission or the competent supervisory authority regarding the processing of your Personal Data
Changes to the Privacy Notice
We reserve the right to change or supplement this Privacy Notice at any time. Please check our company website for any changes.