Privacy Statement of GASPOOL

Data protection is a matter of trust

GASPOOL is delighted at your interest in our company. Data protection has top priority at GASPOOL. We therefore wish to inform you here about what personal data we collect from you, what we do with it and how we protect it. We also inform you about the rights you have as regards protection of your data. 

1. Who we are

GASPOOL Balancing Services GmbH (“GASPOOL“, “we”) is an associated company of GASCADE Gastransport GmbH, Gastransport Nord GmbH, Gasunie Deutschland Transport Services GmbH, Nowega GmbH and ONTRAS Gastransport GmbH and is headquartered in Berlin. 

The purpose of the company is to run GASPOOL’s market area in Germany. The market area comprises around 350 downstream natural gas transport networks. Open Grid Europe GmbH is involved in the market area cooperation.

GASPOOL is the controller within the meaning of data protection law. Our contact details are:

GASPOOL Balancing Services GmbH
Anna-Louisa-Karsch-Strasse 2
10178 Berlin
Germany
Phone: +49 30 364289-0
Email: infoDies ist das @@gaspool.de
Website: www.gaspool.de

Do you have any questions on this Privacy Statement or about protection of your data? Then please do not hesitate to contact our Data Protection Officer: 

GASPOOL Balancing Services GmbH
Data Protection Officer
Anna-Louisa-Karsch-Strasse 2
10178 Berlin
Germany
Phone: +49 (0)30 364289-654
Email: datenschutzDies ist das @@gaspool.de

2. What is at issue? 

When we process personal data, that means we collect, store, transfer and erase it or use it in another form. By personal data, we mean information on natural persons, such as on 

  • contact persons for GASPOOL customers; 
  • prospective customers who obtain information on what we offer on our website. 

Personal data is only collected when you provide us with this information, for example, in connection with registration, completing forms or sending emails, services, queries or requests for material. 

3. How do we process your data when you visit our website?

Whenever you use our website, we and third parties automatically collect data sent by your browser. 

Processing of data when you visit our website

Whenever you visit our website, general data is collected automatically (i.e. not as part of a registration process). This information is not used for personal identification. The web servers used store the following by default:

  • the website from which you access our site;
  • the web pages you visit on our website;
  • the IP address of the computer system calling the site.

The data is processed on the basis of a weighing of interests that always takes your interests into account (Article 6 (1) sentence 1 point (f) of the General Data Protection Regulation (GDPR)). If our offering is used unlawfully, the log data can also help in investigating potential breaches of the law. 

This information is analysed in anonymised form. It is used exclusively to improve the attractiveness, content and functionality of our website. Whenever data is passed on to external service providers, technical and organisational measures are in place to ensure that data protection legislation is adhered to. 

Cookies

We do not use cookies on our website.

4. How do we process your data when you apply for a job online?

The personal data given to us as part of an online job application is collected, processed and used by us confidentially in compliance with the GDPR. Your personal data is processed to examine your application and, if applicable, to establish an employment relationship between you and us (Article 6 (1) point (b) GDPR and Section 26 of the German Federal Data Protection Act (BDSG)).

If your application is successful, we store your application documents in our HR management files. Otherwise, your online application is erased after six months at the latest. 

If you would like us to retain your online application for longer so that we can contact you again at a later date, we require your consent to that. We store your application data in our internal applicant management system for two years if you give us your consent to that (Article 6 (1) point (a) GDPR).

However, we store the basic data of your application, i.e. your name, the date of your application and the outcome of the application procedure, including the reasons for that, for three years beyond the end of the application process so that we can identify repeated applications. The legal basis for processing the data in this way is Article 6 (1) point (f) GDPR.

5. How do we process your data for newsletters and press mailing lists?

On our website, you can subscribe to a free newsletter in which we inform you about matters related to the market area manager, industry-specific topics, and invitations to events. You can also ask to be included in our press mailing list so that you can receive our press releases by email.

We use the double opt-in procedure for subscription. After you have subscribed, an email is first sent to the email address given by you, asking you to confirm your subscription. Your email address is stored for the purpose of sending the newsletter or press releases only if you confirm your subscription within the specified time. We also store the times of your subscription and confirmation. The purpose of this procedure is to prove that you have subscribed and to clarify any possible misuse of your personal data.

The legal basis for processing of your data is your consent in accordance with Article 6 (1) sentence 1 point (a) GDPR. You can object to your email address being used to send the newsletter or press releases, i.e. withdraw your consent, at any time. You can find a link to cancel your subscription at the end of every newsletter.

6. How do we process your data when you use a platform operated by GASPOOL?

We provide balancing group managers and network operators with platforms for handling processes as part of balancing group and control energy management on our website. Specifically, we operate a balancing group portal (“GASPORTAL”) and tendering platform. You can only use the tendering platform if you have previously been granted permission to use GASPORTAL.

6.1 Use of GASPORTAL

If you are a company and wish to register for GASPORTAL, you must provide user data for at least one employee from your company. The data you usually disclose as part of that is:

  • Form of address/title
  • First name
  • Surname 
  • Email address
  • Phone number
  • Position at the company

On the basis of that user data, we generate access data (user name and password) and create a user account. You can also create multiple user accounts by giving us the user data of further employees. In that case, we generate further access data. 

You can apply for your contact data to be included in a list of traders on the GASPOOL HUB or a list of contact persons that is published on GASPORTAL for other registered users. You can also apply to receive market information, such as information on system problems, from us by email. The following contact data of an employee of your company is processed for those purposes: 

  • Form of address
  • First name
  • Surname
  • Email address
  • Phone number
  • Fax number
  • Address data of the company

6.2 Use of the tendering platform 

The following information must usually be provided for employees of the company who are to be able to use the tendering platform:

  • Form of address
  • First name
  • Surname 
  • Email address
  • Phone number
  • Fax number
  • Mobile number

On the basis of this user data, we in turn generate access data (user name and password) and create a user account for the tendering platform.

As part of registration for the tendering platform, we also collect the following data of a commercial contact person at your company:

  • First name
  • Surname
  • Phone number
  • Fax number
  • Mobile number
  • Email address

In addition, the following contact data – if different from the above data – must be provided for a person who can be contacted 24 hours a day, 7 days a week:

  • Phone number
  • Fax number
  • Mobile number
  • Email address

6.3 Cookies

We do not use cookies on our portals. Cookies help make our offering more user-friendly, more efficient and more secure. Cookies are text files that are stored in or by the web browser on your computer. They contain a character string that allows your system to be identified unambiguously when you call the website again.

We use cookies only if that is necessary for an application on the website. Some cookies remain stored and enable us to recognise your browser when you visit our website again. The following data is stored and transmitted by the cookies:

  • Language settings;
  • Internal user ID

6.4 Legal basis

The processing described in this section is based on a weighing of interests that always takes your interests into account in accordance with Article 6 (1) sentence 1 point (f) GDPR. The purpose of and our interest in processing the user data is in particular to enable us to reliably assign the accounts registered for the platforms to a specific contact person of our contractual partners. That is the only way we can ensure that only authorised users from registered companies gain access. It may be necessary to process contact data so as to ensure contact persons can be reached adequately, enable communication between users of the platform and provide information. 

7. Do we use your data for purposes of security?

We also use your data to ensure your security and the security of our services and business processes. To permit that, we process your data in the following cases in particular:

  • To examine the facts of a matter in the case of legal disputes and to assert claims;
  • To be able to ensure IT security and IT operations at GASPOOL;
  • To prevent and investigate criminal offences;
  • To ensure proper business controlling.

The processing described in this section is based on a weighing of interests that always takes your interests into account in accordance with Article 6 (1) sentence 1 point (f) GDPR.

8. Who receives your data?

Your data is only passed on to third parties if you have given your consent to that or there is a legal obligation to do so. 

That means recipients of personal data may also be public bodies and institutions, if there are statutory or official obligations to disclose the data.

Service providers we have engaged may also obtain such data if they meet the special requirements governing confidentiality. In particular, they may be companies that offer IT services, consulting and sales and marketing services. Agreements on data protection, in particular complying with Article 28 GDPR, are then also concluded with these service providers.

9. When do we erase your data?

In principle, we process and store your personal data for as long as we have a business relationship with you.

We erase your personal data if we no longer need it for the original purpose for which we collected it. That does not apply if it has to be further processed – for a limited period of time – for other purposes. Such purposes may be: 

  • Compliance with retention and documentation obligations, for example pursuant to the German Commercial Code (HGB), German Fiscal Code (AO) and German Money Laundering Act (GwG). The retention and documentation periods stipulated by them range from two to ten years.
  • To preserve evidence under statutory limitation regulations. Pursuant to Sections 195 et seq. of the German Civil Code (BGB), this period is usually three years, but may also be up to 30 years in certain cases.

If a different storage period is defined for certain services, you can find details of that in the description of the service in question.

10. Is your data transferred to a third country or international organisation?

In principle, your personal data is not transferred to international organisations or third countries (countries outside the European Economic Area (EEA)). 

11. Are you obliged to give us certain personal data? 

Yes, that may be the case in some circumstances. We need the following personal data from you as part of our business relationship: 

  • Data required to establish, perform and end a business relationship;
  • Data we are required to collect by law. 

We usually cannot conclude or perform a contract with you if we do not have this data. If you do not provide us with the required information and documents, we are not permitted to enter into or continue the business relationship you request. 

12. What rights do you have as regards processing of your data?

You have the following rights via-à-vis us as regards personal data concerning you:

  • The right to access to and information about the data;
  • The right to rectification and erasure of it;
  • The right to restriction of processing;
  • The right to data portability;
  • The right to withdraw consent you have granted.

If personal data is processed to safeguard our legitimate interests (Article 6 (1) sentence 1 point (f) GDPR), you have the right to object to processing of personal data concerning you at any time with future effect. If you object, we must refrain from any further processing of your data for the above purposes, unless

  • there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or
  • processing is required for the establishment, exercise or defence of legal claims.

In connection with processing of your personal data, you also have the right to lodge a complaint with the following data protection supervisory authority responsible for us: 

Berliner Beauftragte für Datenschutz und Informationsfreiheit    
(Berlin Commissioner for Data Protection and Freedom of Information)
Friedrichstr. 219
10969 Berlin
Telephone: +49 30 13889-0
Fax: +49 30 2155050
Email: mailboxDies ist das @@datenschutz-berlin.de 
Homepage: www.datenschutz-berlin.de

13. To what extent is automated individual decision-making used?

In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and conduct a business relationship as part of our website. 

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GASPOOL publishes new Balancing Group Contract Terms & Conditions, valid from 1 June 2019.

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