Comtrade’s privacy policy ifa fair 2024

This Privacy Policy aims to inform you about the data processing in connection with our participation at the 2024 IFA fair in Berlin taking place at Messe Berlin, in Hall 22, booth no 204, during period 6-10 September 2024. The processing of personal data takes place exclusively within the framework of the respective valid legal data protection regulations, in particular the General Data Protection Regulation (hereinafter referred to as “GDPR”).

1 Personal data

In accordance with Art. 4 (1) GDPR, “personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”); a natural person is considered as being identifiable, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics expressing the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

2 Controller

The controller within the meaning of Art. 4 (7) GDPR is

Comtrade Distribution Ltd.

Letaliska cesta 29 B, 1000 Ljubljana, Slovenia
E-Mail: office.slo@comtrade.com

3 Data Protection Officer

You can contact our Data Protection Officer at the postal address listed under section 2 or by sending an e-mail to: dejan.perkovski@tesla.info; contact phone: +381 65 209 6909.

4 Collection of your data

If you visit our booth at the 2024 IFA fair in Berlin (taking place at Messe Berlin, Hall 22, booth no 204), we will collect your data if you provide us with such, e.g.:

by handing over your business card or providing your data in another way (e.g. verbally or in writting) at our booth in which case we will process your name and surname, name of the company in which you are employed or engaged, e-mail address, phone number, and other information you provide;
through the SmartScan App if you allow us to scan your visitor badge at our booth and if you have registered for using the SmartScan app.

In such case we will process your name and surname, name of the company in which you are employed or engaged, e-mail address, phone number, and other information you provided within your registration for the use of the SmartScan app.

In this case we will receive your data through the SmartScan App which is offered and operated by the company LiveBuzz Ltd., Norfolk House, 47 Upper Parliament Street, Nottingham, England NG1 2AB, company no. 07496832. Please note that Comtrade does not control the SmartScan App and this Privacy Policy does not apply to it. Please consult the terms and conditions and privacy policy of the SmartScan App and LiveBuzz Ltd. to find out how your data is collected and used.

5 Processing of your data

We process these data to respond to your concern, e.g. contact for further discussions, potential business cooperation or offers or for providing you further information on our products. If this is necessary to respond to your concern (e.g. when requesting a contact abroad), we will forward your data to the responsible person of the respective company of the Comtrade Group.

We have a legitimate interest in answering your enquiries and pursuing potential business cooperation. The legal basis for the data processing is Art. (6)(1)(f) GDPR. If the purpose of your request is to conclude a contract, the legal basis is Art. 6 (1)(b) GDPR. If you give us your consent for such, the legal basis is Art. 6 (1)(a) GDPR. You may revoke your consent at any time with effect for the future.

If and insofar as you have given us your consent for advertising and marketing purposes, e.g. you have signed up to the e-mail newsletter, customer satisfaction surveys, etc., the data processing required in the context of establishing contact takes place on the legal basis of your consent, Art. 6 (1)(a) GDPR. You may revoke your consent to us at any time with effect for the future (e.g. by using the unsubscribe link included in the e-mail). It might be possible that commercial communication will be provided through our external service providers. These service providers act as instruction-bound processors for us.

Your personal data will not be part of automated decision-making of profiling.

6 Sharing of your personal data

Within the context of the data processing described in this privacy notice, it might be possible that we transfer personal data to the following categories of recipients (in addition to the recipients expressly stated in this privacy notice):

authorized agents and other consultants (e.g. attorneys, tax accountants, auditors);
service providers (e.g. marketing agencies, IT service providers);
other entities in the Comtrade Group or selected third parties that we work with;
state agencies and governmental bodies.

We only transfer personal data to third parties insofar it is required to fulfil our contractual obligations, in case we have or the respective third party has a legitimate interest in processing the personal data or if you have given consent to the transfer. Furthermore, we only transfer personal data to third parties if and insofar we are obligated to do so according to applicable law, regulatory action or court order.

7 Transfer of your personal data

Our processing of your personal data may involve the transfer, storage, and processing of your personal information to other countries where necessary; such countries include, without limitation, countries in the European Union and the European Economic Area, the United States of America, the United Kingdom and Switzerland. Some countries have been determined by the European Commission to adequately protect your personal data. You can find a list of those countries here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. Please note that the data protection laws and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country. We will take appropriate measures as set forth in Art. 46 (2) GDPR and other applicable law, to ensure that your personal information remains protected. Such measures include the use of Standard Contractual Clauses to safeguard the transfer of data outside of the EU, and EEA. To request more information or to obtain a copy of the Standard Contractual Clauses, contact us. Please address your request to the contact details given in sections 2 and 3.

8 How long we will keep your personal data

We will not keep your personal data for longer than is necessary for the purpose for which it was collected. This means that the data will be destroyed or erased from our systems when it is no longer required.

We take appropriate steps to ensure that we process and retain information about you based on the following logic:

At least the duration for which the information is used to provide you with a service;
At least the duration as required by applicable law, contract or in view of our legal obligations;

Only for as long as is necessary for the purpose for which it was collected, is processed, or for longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards;

Where your data is processed based on your consent we process and retain your data for as long as is necessary for the purpose for which it was collected or until you withdraw your consent (whereby such withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal).

9 Data subject rights

Data subjects have various rights under GDPR. These include in particular:

Right of access: According to Art. 15 GDPR, you have the right to request a confirmation as to whether personal data concerning you is being processed by us and, where that is the case, access to the data;
Right to rectification: According to Art. 16 GDPR, you have the right to rectification and/or completion if the processed personal data concerning you is incorrect or incomplete;
Right to erasure: According to Art. 17 GDPR, you have the right under certain circumstances to demand the deletion of your personal data;
Right to restriction of processing: According to Art. 18 GDPR, you have the right under certain circumstances to request that the processing of your personal data be restricted;
Right to data portability: According to Art. 20 GDPR, you have the right to receive the personal data that you have provided in a structured, common and machine-readable format and to transmit it without any obstruction from us to another controller;
Right to object: According to Art. 21 GDPR you have the right to object to processing based on point (f) Article 6(1) GDPR (Legitimate interest of the controller) and to processing for direct marketing purposes, including profiling.

To assert the aforementioned rights or to withdraw any consent for the processing of your data, please contact us stating your concern and your name and address. Please address your request to the contact details given in sections 2 and 3.

10 Right of appeal

You have the right to complain about the handling of your personal data by the data protection authority responsible for you or us.

For your complaint please contact:

the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, e-mail: mailbox@datenschutz-berlin.de, phone: +49 30 13889-0.

Please find further information here: https://www.datenschutz-berlin.de/ ; or

the Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana, Slovenia, e-mail: ip@ip-rs.si, phone: +386 1 230 97 30.

Please find further information here: https://www.ip-rs.si/ .

11 Right of objection

If your personal data on the basis of legitimate interests are processed pursuant to Art. 6(1)(f) GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided there are reasons for this arising from your particular situation, Comtade cannot demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or if your objection is based on being targeted to personal advertising. In the latter case, you have a general right of objection.

Please address your request to the contact details given in sections 2 and 3.