Comfy-Siemens Privacy Notice

Last Update: June 15, 2020

Protecting the security and privacy of your personal data is important to Siemens AG and the Siemens regional company whose Siemens Real Estate unit operates your office location (“Siemens”, “we” or “us”). Therefore, Siemens operates the SIEconnect Comfy app (“App”) in compliance with applicable laws on data protection and data security.

This Comfy SIEconnect Privacy Notice (“Notice”) informs you about the processing of your personal data taking place when you use the App and certain further, browser-based apps accessible from withing the App.

Please note that certain functions described in this Notice will only become available at a later point in time. Moreover, separate browser-based apps accessible from within the App may be subject to a separate privacy and/or terms of use or consent requirements and may only be available for use in certain countries.

Categories of personal data processed, purpose of the processing, legal basis and data controller

When you use the App, Siemens processes the following personal data about you:

1.     App Operation

·       Personal data used to set up your user account and grant you access to the App: first name, last name and e-mail address.

·       Information that is automatically sent to us by your web browser or device, such as your IP-address or other device identifier, device type, browser type (if applicable), referring site, sites accessed during your visit, the date and time of each visitor request.

The data controller responsible for the processing of the personal data described above is Siemens AG, Germany.

2.     Seat Reservation (separate app, browser-based)

·       Your request to reserve a seat

·       Date and time of reservation request

·       Your preferred locations

The data controller responsible for the processing of the personal data described above is Siemens AG, Germany.

3.     User Requests for workplace settings

·       Information concerning requests you submit via the App (“user requests”):

·       Content of the user request (e.g. to control the temperature and lighting your workspace; to find and book meeting rooms; to request repairs; to view available amenities; to view maps of buildings and campuses, etc.)

·       Information about the location which you submitted the request from (building, floor, zone, space type)

·       Date and time of a user request

·       User preferences for the workplace settings that are controlled by the App

The data controller responsible for the processing of the personal data described above is the Siemens regional company whose Siemens Real Estate unit operates your office location.

We process your personal data for the following purposes:

·       To verify your identity.

·       To offer the app’s services and functions and to administer your use of the App.

·       To answer and fulfill your specific requests.

·       As reasonably necessary to enforce our terms of use, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on Siemens’ information technology systems.

We only process your personal data if we are permitted by applicable law to do so. In particular, if you are based in the European Economic Area, the legal basis for Siemens processing data about you is that such processing is necessary for the purposes of:

(i)         legitimate interests pursued by Siemens (Article 6 (1) (f) General Data Protection Regulation), and/or

(ii)        compliance with Siemens’ legal obligations (Article 6 (1) (c) General Data Protection Regulation).

The legitimate interest pursued by Siemens in relation to our use of your personal data is the efficient operation, management and support of the App.

App permissions

The use of certain functions of the app may require you 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: location data

The permissions are required for the following purposes: To identify for which room the user request is

You may manage the use of App permissions in the section “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 do not grant or deactivate the respective App permission.

Transfer and disclosure of personal data

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

·       Third parties providing services to you if you requested their services via the App, to the extent necessary to provide the respective service to you.

·       The service-provider providing the App services to you. This service provider acts as a data processor under instructions of Siemens and is contractually bound to act in compliance with applicable data protection law.

·       Courts, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of legal claims.

Please be aware that sometimes the recipients to whom Siemens 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 and if required by applicable law, Siemens takes measures to implement appropriate and suitable safeguards for the protection of your personal data. In particular:

·       We share your personal data with Siemens companies in such countries only if they have implemented the Siemens Binding Corporate Rules („BCR“) for the protection of personal data. Further information about the Siemens BCR can be found here.

·       We transfer personal data to external recipients in such countries only if the recipient has (i) entered into EU Standard Contractual Clauses with Siemens, (ii) implemented Binding Corporate Rules in its organization or (iii) – in case of US recipients – the recipient is certified under the Privacy Shield. You may request further information about the safeguards implemented in relation to specific transfers by contacting dataprotection@siemens.com.

Retention periods

Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary (i) for the purposes for which they were collected or otherwise processed, or (ii) to comply with legal obligations .

Your rights

The data protection law applicable to Siemens when processing your personal data may entitle you to specific rights in relation to your personal data. You can find out more about those rights by contacting dataprotection@siemens.com.

In particular and subject to the respective statutory requirements you are entitled to:

·       Obtain from Siemens 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 from Siemens the rectification of inaccurate personal data concerning you;

·       Obtain from Siemens the erasure of your personal data;

·       Obtain from Siemens 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.

Further information for US employees

If you are a U.S. resident, then depending on the state in which you reside, you may have special rights with

respect to your personal data. For information regarding any of those rights, please click here.

Data Privacy Contact

The Siemens Data Privacy Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights. The Siemens Data Privacy Organization may be contacted at dataprotection@siemens.com.

The Siemens Data Privacy Organization will always use best efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the Siemens Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.

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Contact a Comfy expert!