Privacy
STULZ ASIA HUB PTE. LTD. Privacy Statement regarding the use of the website (“Privacy Statement”)
www.stulzasia.sg
– Information presented herein is in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”) and relevant subsidiary legislation, codes and regulations, and is meant to apply to all our customers accessing and using our website in Singapore.
1. Introduction
This Privacy Statement shall inform you as to which of your personal data we, STULZ Asia Hub Pte. Ltd., collect, use and disclose as part of the use of our website www.stulzasia.sg (“Website”) (hereinafter referred to collectively as “Processing”). We process personal data in order to contact individuals regarding inquiries, support, or updates relevant to the services or products they are interested in and to perform data analysis for internal reporting, ensuring the data is anonymized or aggregated when appropriate in order to enhance the quality of our services and products. In this context, personal data shall refer to any information relating to an individual, like yourself, who can be identified from that data, or from that data and other information to which an organisation has or is likely to access, including your name, email, contact number, the name of the company you are employed by and its address, and the information regarding the nature and purpose of your inquiry. (“Personal Data”). Personal data is collected by us if you, among other activities, fill up our web form on the Website to obtain information, subscribe to newsletter through the website; when apply for a position through our website personal data related to your application is collected. By accessing and using our Website and services, including by contacting us to enquire about our products and services and proceeding to engage with us or continuing to use our products and services, you voluntarily and expressly consent to our collection, use, and transfer of your Personal Data in accordance with the terms of this STULZ’ Privacy Statement as follows:
2. Organisation
STULZ Asia Hub Pte. Ltd.(“we” or “us”) is responsible for the processing of Personal Data which you provide us as you use our Website. Our contact information is as follows: STULZ Asia Hub Pte. Ltd., Ampat #05-04 KA Centre, 150 Kampong Ampat, Singapore 368324, info@stulzasia.sg. For additional information, please see the Website’s legal notice (Imprint).
3. Purpose
We process Personal Data for the following purposes:
- for us to provide you with information you have expressly requested for;
- for us to provide our services when you subscribe to such services based on the agreed terms and conditions between yourself and us;
- for us to provide you with marketing information on products or services we offer that is related to the services subscribed by you;
- for us to monitor website traffic, performance, and engagement metrics;
- for us to collect applications and manage recruitment processes.
The provision of your Personal Data to us is voluntary where you require information about us and/or our services. If you do not provide such Personal Data, we will not be able to provide the information you require and you may not be able to use all functions of the Website. However, where you have subscribed to our services, the provision of your Personal Data is mandatory in order for us to provide the services and perform our contract with you.
4. Data protection officer
The details of our data protection officer are as follows:
Name: Maximilian Kressner
Designation: Data Protection Officer
Phone number: +65 6408 8000
Email address: maximilian.kressner@luther-lawfirm.com
You can reach our data protection officer by email or by writing to our mailing address (to the attention of the “Data Protection Officer”).
If you have any questions, concerns or suggestions related to the topic of data protection on the Website, you may contact the Data Protection Officer at any time. Using the contact information as provided for our Data Protection Officer, you may also assert your rights as a data subject. Please see Section 10 of this Privacy Statement for more details.
5. Automatic data processing during your visit to our Website – purposes and legal bases
You can visit the Website and gather information without having to provide any personal data (e.g., by registering or transmitting data through online forms). In order to allow you to use the Website in a manner that is user-friendly, stable and safe, and to provide you with additional services, we will, however, automatically process the (pseudonymous) technical data needed for this purpose with help from both your device and browser. (please read clause 5.1 below).
5.1. Automatic data collection and processing by web server (“Web Server Data”)
In order to show you the individual pages of the Website, our web servers automatically process the following personal data, which are transmitted by your browser:
• page visited on Website (URL)
• user agent ID that may contain additional information (about operating system, browser type and version used, preferred language), depending on browser
• referrer URL (page visited most recently, if available)
• date, time and time zone of server request
• IP address
• host name of your Internet service provider (ISP)
The data processing in question is needed for the implementation of pre-contractual measures adopted at your request as such pre-contractual measures also include website visits.
Our web servers temporarily store the (pseudonymous) technical communication data collected and processed for the use of the Website in so-called server log files. Such data will not be evaluated with respect to a specific person, nor will they be combined with data from other sources. We use the server log files for internal system-related purposes; chief among them is ensuring the stability and security of our web servers and the Website. Whenever there is reason to suspect that our offerings are being used in an unlawful manner, we reserve the right to identify and track inadmissible or exploitative attempts to access our web servers using the IP address on file. The legal basis for data processing of this kind is Part 3 of the First Schedule of the PDPA, which permits personal data to be processed in keeping with our legitimate interests. Our legitimate interests are to ensure the Website’s easy administration and safe operation, and to protect our customers’ safe access to our Website.
5.2. Direct marketing
When you contact us, whether through your email to us or via our online contact forms, we will ask you for your further consent that we contact you for the purpose of directly marketing our products and services to you, including but not limited to an email newsletter or postal advertising.
The legal basis for our processing of your Personal Data for marketing purposes is that we have a legitimate interest in obtaining your views, including via market surveys, on how we may improve our products and services and/or tailor our products and services to your specific needs.
By using our Website, such as signing up for updates on our products and services, you consent to our processing of your Personal Data as needed to inform you about our products and services, as well as our enterprise, by email newsletter. You may freely withdraw your consent at any time and cancel your email newsletter subscription. For this purpose, simply send a message to the data protection officer described in Section 4 of this Privacy Statement.
To send out our email newsletters, we employ the Intuit Mailchimp, which registered address is 405 N Angier Ave. NE. Atlanta, GA 30308 USA.
As you provide us with your email address through using the contact forms on our Website, and/or sign up to receive our email newsletters directly (where applicable), you would also have read our Data Protection statement, and given us your consent for Mailchimp to have access to your Personal
Data. Where Mailchimp has access to your Personal Data, however, please be assured that we continue to have complete control over the access and use of your Personal Data by Mailchimp, and will ensure that Mailchimp complies with the regulations and legislations contained in the PDPA in their use of your Personal Data.
5.3. Your contact with us, and our customer service to you
You may contact us through our email address, telephone number or mailing address which we provide on the Website, or by using a contact form (i.e. when you sign up to receive information about our products and services or additional materials). By doing so, you are providing us with access to your Personal Data, and consent to our use of your Personal Data as relevant and necessary.
We use your Personal Data for the purpose of communicating with you to address your concerns and/or enquiries when you reach out to us, including in respect of our products and services. We may also use your Personal Data for purposes incidental but nevertheless in relation to your purpose for reaching out to us.
We will not transfer your Personal Data to a third party unless you consent to such transfer and/or where it is necessary, such as when we forward your Personal Data to the responsible authorized STULZ partner and/or the responsible STULZ subsidiary for the purpose of processing your enquiry, or to inform you about our products, services, and events. Please note that you are entitled to revoke your consent at any time by sending a message to our data protection officer at the address stated in Section 4 of this Privacy Statement.
5.4. Cookies, web analytics tools and external contents
In order to make visiting the Website a user-friendly and attractive experience, and to facilitate the use of certain functions, we use cookies and other technologies that track information concerning your use of the Website. For this purpose, we also employ third party services that allow us, in particular, to analyze your use of the Website and to show you necessary information from third party websites.
We deploy the cookies needed for certain functions of the Website on the basis of our legitimate interest in providing and optimizing our offerings. Where your further consent is required for the use of cookies and tools serving marketing or web analytics purposes as well as media services offered by external providers, we will ask you for your consent accordingly.
In order to manage your consents, we have integrated within the Website the Usercentrics service (“Usercentrics”) provided by an external third party, Usercentrics GmbH, which registered office is at Sendlinger Strasse 7, 80331 München, Germany. Usercentrics allows you to grant your consent for certain data processing processes, as well as to withdraw your consent when you wish to do so. In addition, Usercentrics assists us with documenting your relevant declarations. For this purpose, log data on the status and timing of your declarations of consent are processed in addition to the log file data mentioned in Section 5.1. Such processing of Personal Data is needed for us to document any consent granted.
You can find information about the cookies and similar tools used on the Website as well as on the consents you have granted under “Privacy settings” at any time. This is where you may manage the consents granted and withdraw them, be it wholly or in part.
5.4.1. Cookies
We use so-called cookies on our Website to make certain functions available or more attractive. Cookies are small text files that are stored on your end device. Some of the cookies we use (so-called session cookies) are deleted once the browser session ends – i.e., when the browser is closed. Other cookies (so-called persistent cookies) remain on your end device and allow us to recognize your end device upon your return.
You can adjust your browser settings in order to be notified of cookies to be stored, so you can decide whether to accept cookies on a case-by-case basis – or block them in certain instances or as a rule. You can also choose a browser setting that ensures that cookies are automatically deleted when the browser is closed. The non-acceptance of cookies may compromise the Website’s functionality. Otherwise, you may also delete the cookies after your visit to our Website.
For details about the cookies and services we use, please refer to “Privacy settings.” The legal basis for our use of cookies on our Website is due to technical reasons, namely, in maintaining the Website’s full functionality.
You may withdraw your consent to the use of non-essential cookies and tools in “Privacy settings” at any time, be it wholly or in part. For more information about the non-essential cookies and services used, please refer to “Privacy settings” as well as the following sections of this data protection declaration.
5.4.2. Google Analytics
For purposes of measuring reach and analyzing your user behavior, as well as of evaluating and improving the Website, we use the web analytics service Google Analytics of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google Analytics”) developers.google.com/analytics on the Website. Google Analytics is not activated until you have given your consent in the category “Analysis” under “Privacy settings”.
The service deploys cookies that allow your user behavior to be analyzed. During your visit to the Website, the following information may be collected: start of session, initial visit to Website, pages visited, interaction with Website (click/scroll path), internal search queries, clicks on external links, videos viewed, files downloaded, ads viewed and clicked, language setting. In addition, Google Analytics gathers the technical communication data mentioned in Section 5.1, including your IP address.
You may deactivate your consent at any time under “Privacy settings.” And you may put a stop to cookie-based data processing as part of Google Analytics using any of the following options:
- You prevent Google’s cookies from being stored by adjusting your browser settings accordingly; we shall note, however, that if you do so, some of the functions of the Website may not be available to you to their full extent.
- You can also prevent Google from receiving and processing the data generated by the cookies about your use of the Website (which include your IP address) by downloading and installing the browser plug-in available here: tools.google.com/dlpage/gaoptout.
We also use the Google Signals function with Google Analytics on our website, also with activation of IP anonymization. We receive statistics without personal data via Google Signals. If you have activated ads personalization in your Google account and your devices are linked to your Google account, Google can analyze your usage behavior across devices and generate reports. You can change the ads personalization settings in your Google Account to prevent cross-device tracking, by accessing this website: support.google.com/My-Ad-Center-Help/answer/12155764.
For additional information about the terms of use of Google Analytics, please visit marketingplatform.google.com/about/analytics/terms/de/; about Google Signals visit support.google.com/analytics/answer/7532985, for more information about data protection, please visit policies.google.com/technologies/partner-sites; Google’s data protection policy is found here: policies.google.com/privacy.
5.4.3. Google Tag Manager
We use Google Tag Manager on our website. The provider of the Google Tag Manager is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager allows us to play out and manage tools (e.g. Google Analytics) on our website. While Google Tag Manager does not itself collect Personal Data, the tools played via Google Tag Manager may in turn set cookies in your browser and process Personal Data. Google Tag Manager itself processes your IP address, which may also be transmitted to Google servers in the USA.
If deactivation has been made at the domain or cookie level, it will persist for all tracking tags implemented with Google Tag Manager. Google's privacy policy for this tool can be found here: www.google.com/analytics/terms/tag-manager/
5.4.4. YouTube videos
We have integrated videos from the YouTube video portal, which is operated by Google (see Section 5.4.2). For this purpose, we avail ourselves of the option “extended data protection mode” provided by Google (i.e. no data about you as a user will be transmitted to YouTube if you do not play the videos; only when you play the videos will such data be transferred to YouTube). Data processing in turn requires that you have granted your consent in the category “Functional/external media” under “Privacy settings.” Stulz has no control over the use of personal data by Google and is not responsible in this respect. The consent is given directly to Vimeo and Stulz Asia Hub is not the data user in this regard. Stulz Asia Hub has no control over the use of personal data by Vimeo and is not responsible in this respect.
If you did so consent, a connection is established with the Google servers, with contents being streamed on the Internet page following a message sent to your browser when you open a page featuring an integrated YouTube video. In the process, your IP address, device information as well as data about the website opened will be transmitted to Google. If you are simultaneously logged in with another Google service, such information may be matched to your membership account. You can prevent this from occurring by logging out of your membership account prior to visiting the Website.
Once you start playing an integrated video, Google will only store cookies on your device not containing personally identifiable data in “extended data protection mode” unless you are currently logged in to a Google service. These cookies may be blocked through appropriate browser settings and extensions.
We have no influence on the transfer of your data to YouTube/Google once you play an integrated YouTube video on our Website. For more information about data protection in connection with YouTube, please refer to Google’s data protection policy: policies.google.com/privacy.
5.4.5. Vimeo videos
We have integrated videos of the provider Vimeo LLC, located at 555 West 18th Street, New York, New York 10011, USA, on our Website by means of a plugin (Vimeo plugin) for the display of videos.
We have set up the integration of these videos in such a way that a connection to the Vimeo servers is not automatically established when you call up a page on our Website on which a video is integrated using the Vimeo plugin. For this purpose, the setting of cookies is deactivated by default for the embedded videos.
If you want to start the respective video, a connection to the Vimeo servers is required. In the process, your personal data in the form of your IP address, technical information about the end device you are using (e.g. browser type, operating system, basic device information) and the website you are accessing from will be transmitted to Vimeo's servers in the U.S. By playing a video from Vimeo, you explicitly consent to the transmission of your Personal Data to Vimeo, and its servers in the U.S. The consent is given directly to Vimeo and Stulz Asia Hub is not the data user in this regard. Stulz Asia Hub has no control over the use of personal data by Vimeo and is not responsible in this respect.
The data transfer will then take place regardless of whether you have a user account at Vimeo and are logged in there. However, Vimeo can assign your surfing behavior to your user account if you are logged in when you start the video. You can prevent this by first logging out of your user account and deleting the corresponding cookies. You can learn more about how Vimeo handles its users’ data by reading Vimeo's privacy policy at: vimeo.com/privacy
6. Online presences and services
6.1. Social networks
We maintain a vibrant and active social media presence. You can access our respective social media appearance via links from our Website to our pages on, among others, Facebook, LinkedIn, Xing, Instagram, X, YouTube and TikTok. To the extent that your Personal Data may be processed only where necessary, the legal basis for our doing so is that we have a legitimate interest in conveying information to and communication with the users of our Website.
Further, if you follow our social media presence, your social media network or public forum accounts may provide us with information such as your public profile, email address, friends/follower lists on such social media networks and/or public forum accounts.
You can learn more about the necessary data processing conducted and possibilities to object under the following links:
Facebook: www.facebook.com/about/privacy/, facebook.com/settings LinkedIn: www.linkedin.com/legal/privacy-policy, www.linkedin.com/psettings/guest-controls
X: twitter.com/en/privacy
Xing: privacy.xing.com/de/datenschutzerklaerung
Instagram: help.instagram.com/519522125107875
Youtube: policies.google.com/privacy, adssettings.google.com/authenticated TikTok: www.tiktok.com/legal/privacy-policy-eea
6.2. Google Maps
Our Website uses Google Maps. If you consent to the use of Google Maps on a subpage in which Google Maps is embedded and activate the Plug-in, Google receives the information that you have entered into the respective subpage of our Website, as well as the data that your browser transmits (e.g. your IP address, date and time of the query, data volume transferred, operating system und surface, language and browser software version.). Such information may be sent by Google to its server in the U.S, and stored there.
Google collects such information regardless of whether or not you are logged onto your account with Google (or even if you do not have an account with Google). When you are logged in to Google, your data is assigned to your user account directly. Google stores your data as user profiles and uses them for purposes of advertisement, market research and/or needs-based design of the Website.
We have no influence and cannot therefore assume any responsibility for the further processing and use of the data by Google. Should you wish to exercise any right against Google, e.g., a right to object the creation of these user profiles, you must contact Google directly. The Google privacy policy and additional terms of use or Google Maps can be found at www.google.com/intl/de_de/help/terms_maps.html. You can also learn more about Google’s processing of your personal data in Google’s Data Protection Declaration at: policies.google.com/privacy.
7. Sharing personal data
In general, STULZ does not share with third parties the Personal Data which we collect from you during your use of our Website, unless as specifically provided otherwise in this Privacy Statement.
As we have informed you in the foregoing sections of this Privacy Statement, for the operation of the Website, the execution of individual functions and offers, and the service and maintenance of IT systems, we rely to some degree on external service providers that we select with care. To the extent necessary for us to rely on external service providers, these service providers working on our behalf may process your Personal Data, but will do so only in accordance with our instructions under a given contract for the exclusive purposes stated in the data protection declarations in these respective contracts. All external third party service providers are contractually obligated to strictly comply with this STULZ’ Privacy Statement, as well as the PDPA. The same applies to any subcontractor if and to the extent that our processors use subcontractors with our prior consent.
Nonetheless, where we are compelled by law, regulation, governmental request(s), and/or order of court to disclose your Personal Data to such public authorities, government agencies and/or private holders of rights, we must make such disclosure, but only to the extent necessary.
8. Processing personal data beyond Singapore
Personal Data which we collect from you may sometimes be transferred outside of Singapore where absolutely necessary.
Where we are required to transfer your Personal Data to a third party beyond Singapore, we will ensure that we have control over the third party’s use and/or dissemination and/or transfer of your Personal Data. We will not transfer Personal Data to a third party / country beyond Singapore’s jurisdiction that does not provide comparable protection of your Personal Data to Singapore’s PDPA unless the third party is contractually bound to apply appropriate safeguards to the proposed handling of your Personal Data and the third party’s transfer of your Personal Data takes place both in accordance with a standard of protection comparable to the protection afforded under the PDPA (as well as other relevant legislation, subsidiary legislation, and regulations).
Additionally, insofar as you have consented to data processing undertaken by Google and Vimeo services (please see how you may have consented to such data processing by Google and Vimeo at Sections 5.4.2, 5.4.3, 5.4.4 and 6.2 above), the data collected by them will be transmitted, in part, to other companies affiliated with Google and Vimeo and registered in the U.S. – namely Alphabet Inc. and Google LLC – as well as other Google and Vimeo services providers. We do not have influence over how Google and Vimeo process your Personal Data. To learn more about how they do so, please visit Google’s and Vimeo’s respective websites to learn more about how your Personal Data is protected:
9. Length of storage
9.1. Your Personal Data
Your Personal Data which we store in our database will be deleted as soon as it is reasonable for us to assume that the purposes for which the Personal Data was collected are no longer being served by retention of the Personal Data, and retention of the Personal Data is no longer necessary for legal or business purposes.
If you have contacted us through one of our contact forms or by other means (please see Section 5.3 above), the data you provide shall be processed exclusively for the purpose of addressing your concerns and/or any additional questions you might have, and shall be erased thereafter. At the latest, the data will be erased six months after you last made contact.
Should we require your Personal Data to be stored and/or used by us for a longer period of time, we will reach out to you with an explanation of why this should be the case, and for us to request your consent for us to do so.
9.2. Web Server Data
Web Server Data, which is technical communication data contained in the server log files referred to at Section 5.1 above, shall be deleted as soon as it is reasonable for us to assume that the purposes for which the data was collected are no longer being served by retention of the data, and retention of the data is no longer necessary for legal or business purposes. In any event, such data will be deleted after 30 days, at the latest.
9.3. Cookies
Cookies used during each session of your visit to our Website are deleted when your browser is closed. Any persistent cookie we use will remain on your device until their prescribed life span has expired or you remove them manually (please see Section 5.4.1 above). The length of storage for individual cookies is listed in “Privacy settings”. Data collected by Google Analytics shall be deleted upon the anonymization of IP addresses (see Section 5.4.2). By way of an agreement with Google, we have limited the length of storage for data gathered by Google Analytics to be no more than 14 months.
10. Data subject’s rights
10.1. Right of access, rights to rectification, erasure, and restriction in respect of your Personal Data
Our processing of Personal Data is governed by the PDPA, and its subsidiary legislation, including the Personal Data Protection Regulations 2021. More information about your rights to protection of your Personal Data is accessible at the website maintained by the Singapore Personal Data Protection Commission, at www.pdpc.gov.sg
You have the following rights:
- right to request access to your Personal Data that is being processed and/or retained by us on your behalf and to request deletion or correction of inaccurate or incomplete Personal Data;
- right to withdraw your consent to Stulz’ processing of your Personal Data; and
- right to prevent the processing of your Personal Data where such processing is likely to cause damage or distress;
in accordance with applicable law requirements.
We will respond to your requests for access to your information as soon as reasonably possible from the time we receive your request. However, please note that we may charge you a reasonable fee to process your request, which purpose is to allow us to recover the incremental costs of responding to your request- this may include the time and costs incurred to search for the Personal Data requested. We will notify you of the fee that will be chargeable to you after we receive your request, and in any case will not proceed on your request until you have indicated your express consent to pay such fee, and have made payment of such fee.
For the avoidance of doubt, we will not respond to requests for access to third party information (for example, information in respect of another customer).
10.2. Right to lodge a complaint
You have the right to lodge a complaint with the Singapore Personal Data Protection Commission. More information is available at the website of the Singapore Personal Data Protection Commission, at: www.pdpc.gov.sg/Contact-Us
11. Our right to amend this Privacy Statement
We may update this Privacy Statement in accordance with Singapore’s law at any time. We encourage you to check our Privacy Statement regularly for any changes in order to stay informed about how we protect and use your Personal Data.
12. Choice of Law / Dispute Resolution
This Privacy Statement shall be governed by the laws of Singapore. Any dispute that arises out of and/or in connection with terms of this Privacy Statement shall be adjudicated by a competent court of law in Singapore in accordance with the procedural regulations and legislation applicable under the laws of Singapore.