Social Media Privacy Policy

Privacy Policy for the Toshiba Storage Facebook Page

Date: August 2018

Thank you for visiting our Facebook page. The protection of your personal data is very important to us. With this Privacy Policy you can learn about the processing of your personal data when visiting our Facebook page.

I. Who we are and how you can reach us

Facebook Ireland Limited
4 Grand Canal Square
Dublin 2
Ireland

and we,

Toshiba Electronics Europe GmbH
Hansaallee 181
40549 Düsseldorf
privacy@tee.toshiba.de

are jointly responsible for processing your data. For any questions regarding the data processing performed by Facebook and your related rights please contact Facebook’s data protection officer via Facebook’s Privacy Policy https://www.facebook.com/about/privacy/. For any questions about our data processing described in Sec. II. A. below and your related rights, please contact our data protection officer: Data Protection Officer, Mr. Christian Mommers, c/o intersoft consulting services AG, Pempelforter Straße 47, 40211 Düsseldorf Germany, privacy@tee.toshiba.de).

II. Data processing related to your visit of our Facebook page

A. How we process your data

1. Facebook Insights

Description and extent of data processing:
We are using the function “Facebook Insights”. Based on parameters and time periods defined by us, we obtain anonymized statistical data provided by Facebook. We are not able to identify specific persons from this data. The statistical data includes various information, e.g. regarding:

• The activities and interactions (e.g. clicks, views), likes and coverage of our page, our promotion activities, our posts and our events,
• The number and activity time of our subscribers and visitors as well as statistical information on their age, gender and location.
• Video statistics
• Received and sent messages.

Purpose of data processing:
With the help of the statistical data, we gain statistical knowledge about how our Facebook page is used. This enables us to optimize our activities on our page and improve and optimize the design and content of our page, promotion activities, posts and events.

2. Facebook notifications

Description and extent of data processing:
When you interact with our page or one of our posts, promotion activities and events (e.g. like, share, comment), subscribe to our page or follow us we receive a notification by Facebook including your name, your profile picture and your interaction.

This data can be accessed by responsible persons within the Toshiba group as well as third party service providers who support us in the field of Public Relations and Social Media management. These service providers are contractually obliged to comply with data protection requirements and confidentiality. Service providers who are processors have signed a specific agreement to ensure that data is processed strictly in accordance with our instructions.
We are not able to delete the Facebook notifications, your posts or other interactions.

Purpose and legal basis of data processing:
We use the data provided to see how you interact with our Facebook page and to react to your interactions (e.g. comment, like, share). The data processing is based on our legitimate interest to fulfil this purpose (Art. 6 sec. 1 f GDPR).

3. Contact

Description and extent of data processing:
When you contact us via Facebook, we process the information you provide, such as your user name, your profile picture, your concern and your contact details. You can contact us without providing details such as your real name and your contact details.

This data can be accessed by responsible persons within the Toshiba group as well as third party service providers who support us in the field of Public Relations and Social Media management. These service providers are contractually obliged to comply with data protection requirements and confidentiality. Service providers who are processors have signed a specific agreement to ensure that data is processed strictly in accordance with our instructions.

We store the data for as long as it is necessary to fulfil the purpose described below, however, we are not able to delete your posts, comments or other interactions on Facebook.

Purpose of data processing and legal basis:
We process your data to handle your inquiry. The data processing is based on our legitimate interest to fulfil this purpose (Art. 6 sec. 1 f GDPR).

4. Raffles

Description and extent of data processing:
When you participate in raffles on our Facebook page, we process the personal data you provide, such as your user name, your profile picture, your real name and your contact details. We will mention the user name of the winner in a comment and then ask the user to send us the postal address via e-mail.

This data can be accessed by responsible persons within the Toshiba group as well as third party service providers who support us in the field of Public Relations and Social Media management. These service providers are contractually obliged to comply with data protection requirements and confidentiality. Service providers who are processors have signed a specific agreement to ensure that data is processed strictly in accordance with our instructions.

We store your data as long as it is necessary to perform the raffles. However, we are not able to delete your posts, comments or other interactions on Facebook.

Purpose and legal basis of data processing:
We process your personal data exclusively for performing the raffles. The legal basis for the data processing is the necessity to perform a contract (Art. 6 sec. 1 b GDPR).

B. How Facebook processes your data

When you visit our Facebook page, Facebook collects and processes various personal data obtained by Cookies and other tracking technologies and provided by you and third parties, e.g. to create statistics for Facebook Insights, to provide measurement and analytics to advertisers, for market research and to personalize features and content. Facebook shares these data with other Facebook group companies and third parties and transfers data to third countries outside of the European Union like the U.S. For further information on the extent and purpose as well as the legal basis of Facebook’s data processing and your control options please visit Facebook’s Data Privacy Policy https://www.facebook.com/about/privacy/, Cookie Policy https://www.facebook.com/policies/cookies and information https://www.facebook.com/help/568137493302217 on how to adjust Facebook’s use of your personal data.

III. Your rights as a data subject

According to Articles 15 to 21 and 77 of the GDPR and if the legal conditions are met, you are entitled to the following rights. Please notice that we are only able to support you with your rights regarding our data processing described in Sec. II. A. above. To exercise your rights with regard to Facebook’s data processing, please directly contact Facebook.

Information
You may at any time request that Facebook and we provide you with information about which of your personal data are processed and provide a copy of the personal data stored, Art. 15 GDPR. Please note that additional copies of the personal data may be subject to a charge.

Correction
You may request the correction of incorrect personal data and completion of incomplete personal data, Art. 16 GDPR.

Deletion/Erasure
You may request the deletion of your data. However, this right does not apply to data that is needed for the execution of contracts and for the assertion, exercise and defense of legal claims and data that is subject to mandatory retention obligations, Art. 17 GDPR.

Restriction of processing
You may, under certain circumstances, require the restriction of processing, for example, if you believe your data is incorrect, if the processing is unlawful or if you object to the data processing. As a result, your data may be processed only to a very limited extent without your consent, e.g. for the assertion, exercise and defense of legal claims or for the protection of the rights of other natural and legal persons, Art. 18 GDPR.

Opposition to data processing
You have the option to object to data processing for direct marketing purposes at any time. In addition, if you have special reasons, you may object to the data processing that takes place on the basis of a legitimate interest at any time, Art. 21 GDPR.

Withdrawal of consent
You may revoke a given consent to the processing of your personal data at any time with future effect. The revocation does not affect the legality of the previous data processing and that it does not extend to such data processing which is based on another legal ground.

Data portability
You have the right to receive the data you have provided and that we or Facebook process on the basis of your consent or to fulfill the contract in a standard, machine-readable format to request direct transmission of this data to third parties, Art. 20 GDPR.

Right to complain to the Data Protection Authority (DPA)
If you believe that our data processing is unlawful or Facebook or we have not granted the rights described above to the extent necessary, you have the right to file a complaint with the respective DPA.