ETWeb™ empower Knowledge Hub
When you initiate and
login to your ETWeb™ empower Knowledge Hub account and use our knowledge platform we
to help you understand what data we collect and process, and how and for what
purposes we do that.
A. Who are we?
The ETWeb™ empower Knowledge Hub is operated and, accordingly, your personal data is collected and processed by Lumesse GmbH, Flughafenstrasse 103, 40474 Düsseldorf, Germany, firstname.lastname@example.org (“Lumesse”, “we”, “us” etc.). You can contact our data protection officer, Thomas Göser, at Lumesse GmbH, Flughafenstraße 103, 40474 Düsseldorf, email@example.com.
B. What is “personal data”?
Personal data means any
information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
C. Personal data that we
collect and process
In order to operate Knowledge
Hub (also the “Platform”) as well as the website through which you can use the
Knowledge Hub, we need to collect and process certain data (personal data and
We create the Knowledge
Hub user account for you, the designated Knowledge Hub user, on the basis of
the information and personal data your employer or, as the case may be, your
employer’s principal (such as when your employer performs services for another
company that utilises the Knowledge Hub) has transferred to us. The data used
to create your account are your first name and surname (they will make up your
Knowledge Hub user name) and your email address (for communicating with you in
relation to your account). Without this data we cannot create the account, and
without an established user account you cannot use the Platform.
After creating our user
account, we will send you an email that contains a link to a webpage on which
you can set your personal password. Your user name and password are the
credentials with which you can then log into your Knowledge Hub account.
Do not be surprised
that the initial email to you as well as, possibly, other Knowledge Hub related
emails later on will be designated as having been sent by “Atlassian
Confluence” or similar. The ETWeb™ empower Knowledge Hub is based on “Confluence”, a
content collaboration software manufactured by Atlassian. We use an on-premise
installation of Confluence, however, so that when you receive systems email,
they always come only from our designated systems.
2. Using your account
Using your account will
in almost all cases result in additional personal data that we will store and
process in connection with you and your user account.
2.1 First, you can complete
your profile data:
Add an email address, a phone number and/or and an IM
for other Knowledge Hub users in your spaces and projects to communicate with
Add your website
Add information about who you are in your company
Upload your picture
2.2 Second, as you and your
team create content in the Knowledge Hub, the system will reference and
aggregate such content in the “Recently Updated” portion of your profile and,
further, will of course store and apply all preferences and settings that that
you have set/made while using your account (favourites, pages that you want to
watch specifically, file exports that you have initiated etc.)
2.3 And, third, you can of
course create content in the Knowledge Hub and generally be an active user and
contributor which, as your activities are connected to your account, will also
produce personal data.
Subject to Section 3
below, these personal data will only be visible/accessible to you and the other
users that are allocated to your spaces and projects on the Platform. Hence,
while we operate the Knowledge Hub as a platform not only for you and your
employer but also for other Lumesse customers, such other customers and their
designated users cannot see that you are a user, who you are or what you do in
the Knowledge Hub. We keep our customer instances strictly separate from each
information under Section 2.1 will in many cases improve your and your
collaborator’s use of the Knowledge Hub, and whereas the active use of the
Platform is very much the idea behind it, filling out your profile as well as
being active in the Platform is an option, not a must.
3. Maintenance and Support
Certain technical work
that we do on the Platform as well as support requests that we may receive from
you will lead to us having access to your personal data.
3.1 While we generally have
no need to process personal data of our users when we do technical maintenance
work on the Platform, our administrators will in many cases need to take access
to the systems behind the Platform in a way that factually allows them to also
take note of personal data of users.
3.2 When we attend a support
request you may have (incidents affecting the use of the Platform, email
address changes on your part etc.), our support staff will have access, and may
have to take note of, your personal data.
3.3 In some cases certain
staff at our service provider kreuzwerker GmbH who host the Knowledge Hub on
their systems (all located in Germany) may have access to the backend of the Knowledge
Hub to perform certain technical work (incident management etc.) and, in that
context, also may have access to your user account and/or the database(s) that
contain(s) your personal date.
In all three cases we,
and kreuzwerker GmbH, will limit the access to your personal data to the
minimum. kreuzwerker GmbH with whom we, of course, have the necessary
contractual framework in place, will not actively process your personal data.
4. “Typical Internet data”
In addition to the
information typically understood to be personal data (section 1. to 3 above),
we may collect and process certain data as a result of certain technical processes
when you visit the website that hosts the Knowledge Hub and especially when you
login to your account. Such data may be understood to be personal data in
certain cases, and, either way, we want to inform you accordingly.
4.1 General log files
The web server(s) automatically
collect(s) and store(s) certain information in what is known as log files. The
log files contain certain data on the hardware and software of the device that
you use. This information will be stored separately and can and will not be
combined with personal data that we store (such as data on your account). We
use the log files in order to better analyse problems with the availability of
4.2 Logging when you are
using the Platform
When you have initiated
your account and use the Knowledge Hub we will log your log-in and log-out, your
user name, the URLs of the webpages that you are visiting/changing during your
time on the Knowledge Hub, and the respective referrer URL. We log data more
extensively when you are logged on in order to ensure the continued and best
possible operation of the Knowledge Hub for you and to detect and fix any
incidents that may be in the way of providing the best possible service for you
and your employer. The data under this Section 4.2 will remain stored for a
maximum of six (6) months as from your respective Knowledge Hub session.
text files stored locally via your browser on your device) to identify your
browser or your device.
a) We use an authentication
and session cookie (JSESSIONID) to automatically identify your browser or your
device when you log in. The cookie serves as a session cookie. Accordingly, the
following data is
stored in our authentication and cookie: your user credentials as well as the
information on the then-current session. The cookie expires at the end of every
session or when the browser is closed.
b) We use a second cookie
that serves as an identifier that saves you from having to type in your
credentials anew before logging in, provided you have checked the “Remember me”
checkbox. The cookie expires after one (1) year of inactivity in the Knowledge
Hub on your part. You can, of course, also delete the cookie manually at any
c) We may also use
additional Confluence and third-party cookies in order to enable certain
specific functions within the Knowledge Hub (e.g. “Space Privacy” to make a
space that you use invisible for (most) other users, “Refined Theme” in order
to remember certain design settings that you prefer et al.). These functions
You may refuse the use
of cookies by selecting the appropriate settings on your browser. If you want
block any new cookies (also, you can delete existing cookies, of course).
Details about how this can be done in your browser can be found, for instance,
in your browsers’ help section. However, please note that, if you set your
browser to automatically reject all cookies, you will no longer be able to log
into the Knowledge Hub.
D. Why do we collect and
process personal data?
We collect and process
your personal data to be able to offer you and your employer the service that
is our Knowledge Hub, the use of the Knowledge Hub being part of the services
that we provide in performing the corresponding contract with your employer. The
collection and processing of your personal data as described above is therefore
necessary for the
purposes of the legitimate interests pursued by us and by your employer, i.e.
to perform the corresponding agreement with your employer and, vice versa, to
have the agreement perform by us.
E. Third party recipients
1. Subject to Section 2.
below, aside from your employer and the other users who have legitimate access
to your spaces and projects, and aside from the specific circumstances in which
kreuzwerker GmbH may have access (see Section 3.3 above), the will be no
(further) recipients of your personal data.
2. We may also disclose or
share personal data with third parties, if and to the extent necessary to
enforce any claims we are entitled to, if you have given your consent to such
disclosure, and if we are required by law or ordered by a court to disclose
F. Your rights
1. Upon your request we will provide
confirmation as to whether or not personal data
relating to you are being processed and information at least as to the purposes
of the processing, the categories of data concerned, and the recipients or
categories of recipients to whom the data are disclosed; and/or
information on the personal data undergoing
processing, and of any available information as to their source.
2. Further, we will, upon your request,
rectify, erase or block (restriction of processing) all
or part of your personal data if the data or, as the case may be, the processing
of the data do not/no longer comply with the applicable statutory provisions,
in particular because of the incomplete or inaccurate nature of the data; and/or
notify any third parties to whom your personal data
have been disclosed of any rectification, erasure or blocking carried out in
compliance with the preceding paragraph, unless this proves impossible or
involves a disproportionate effort on our part.
For any such requests,
please email us at firstname.lastname@example.org or write us to our mail address
(cf. Section A).
to lodge complaints
You have the right to
lodge a complaint with a supervisory authority, in particular in the EU Member
State of your habitual residence, place of work or place of the alleged
infringement if you consider that the processing of personal data relating to you
infringes the applicable statute.
We reserve the right to
Last amended: September 2017