Privacy policy


GreenCom Networks is committed to a policy of respecting and maintaining high standards of ethics and in particular the protection of personal data.

On the website, implements the processing of personal data as data controller. The identity and contact details of GreenCom Networks are specified in the “Legal Notice” section.

The purpose of this external privacy policy is to inform you about how this data is processed by GreenCom Networks and the extent of your rights.

It may have to evolve according to the applicable legal and regulatory context.


1 – Legal bases and purposes of processing

GreenCom Networks implements various processing operations whose legal bases are as follows: your consent, its legal and regulatory obligations, its legitimate interest.

The purposes associated with each legal basis are listed below:

  • Based on your consent, we carry out processing for the following purposes:
    • the management of cookies subject to consent.
  • Based on compliance with our legal and regulatory obligations, we carry out processing for the following purposes:
    • the management of responses to official requests from public or judicial authorities empowered for this purpose.
  • Based on our legitimate interests, we carry out processing for the following purposes:
    • the management of cookies not subject to consent.

The purposes pursued on the basis of our legitimate interests are pursued in compliance with your rights and freedoms.

If GreenCom Networks is required to process your data for purposes other than those listed in the paragraph below, we will inform you and will take any additional steps that may be necessary.


2 – Data processed

GreenCom Networks undertakes to its customers to collect and process only the data necessary for its activities relating in particular to the provision of the services we offer you, as well as products and services personalized to your profile. As a result, GreenCom Networks collects on the site personal data as follows:

  • surname and first name
  • the e-mail address (email)
  • society


3 – Data subjects

The persons concerned by the treatments are the users of the site

4 – Recipients of the data

To achieve the purposes described above and within the limits necessary for the pursuit of these purposes, the data collected by GreenCom Networks may be transmitted to all or some of the following recipients:

  • the internal services of GreenCom Networks authorized to manage our business relationship (all persons in charge of the award, management and execution of contracts);
  • the persons in charge of the marketing department, the sales department, the departments responsible for dealing with customer relations, complaints, prospecting, administrative services, IT services and their line managers;
  • lawyers, court officers and judicial officers, administrative or judicial authorities seized of a dispute if necessary, in the context of compliance with the legal obligations incumbent on GreenCom Networks or to enable GreenCom Networks to defend its rights and interests;

5 – Data retention period

Respecting the right to be forgotten, GreenCom Networks keeps the personal data it collects only for the time necessary for the purposes of the processing and in accordance with the applicable legislation.

The data collected by GreenCom Networks will, therefore, be kept for the time necessary to achieve the purposes described above, increased by the period of the legal prescription.

Specifically, we organize our data retention policy as follows:


Shelf life

The analysis of your data in particular to personalize the products and services we offer according to your profile, to send you messages, personalized communications or not, concerning our products or services

The data is kept for three (3) years from the last incoming contact

The management of our commercial relationship with you, including responses to contact requests you send us

The entire duration of the contractual relationship, at the end of which only the data necessary for pre-litigation or contentious purposes are archived until the acquisition of the legal prescription. The limitation period under ordinary law in civil and commercial matters is five (5) years. In the event of litigation, these data are kept for the duration of the procedure and until the expiry of the ordinary and extraordinary remedies.

Newsletter membership management

The data is kept until the subscriber unsubscribes

Cookie management

The data retention period may not exceed 13 months


6 – Data security

GreenCom Networks attaches particular importance to the security of personal data.

It has put in place technical and organizational measures adapted to the degree of sensitivity of the personal data, in order to ensure the integrity and confidentiality of the data and to protect them against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties.

GreenCom Networks regularly conducts audits to verify the correct operational application of data security rules.

Thus, it undertakes to take the necessary physical, technical and organizational security measures to:

  • protect its activities;
  • preserve the security of the personal data of its prospects, customers and Internet users;
  • against any unauthorized access, modification, distortion, disclosure, destruction or access to the personal data it holds.

Nevertheless, the security and confidentiality of personal data are based on everyone’s best practices, so you are invited to remain vigilant on the issue.


7 – Transfer of data outside the European Union

GreenCom Networks stores personal data only in the European Union.


8 – Your rights and how they are exercised

8.1 The content of your rights

Any data subject has the following rights related to the data concerning them:

  • right to information;
  • right of access;
  • right to rectification;
  • right to erasure (unless it is necessary for the performance of the services, or it is necessary for us to GreenCom Networks to comply with its legal obligations or to establish or exercise its rights);
  • right to set guidelines regarding the fate of data after the death of the data subject.

Under the right of access, GreenCom Networks may require you to pay a reasonable fee based on administrative costs for any additional copy of the data to that which will be communicated.

You also have:

  • a right to obtain the restriction of processing;
  • a right to the portability of the data provided;
  • a right to object.

You may request to exercise your right to object to the processing of personal data concerning you for reasons relating to your particular situation where the processing is based on the legitimate interest of GreenCom Networks. This right to object also applies to profiling.

In the event of the exercise of such a right to object, GreenCom Networks will cease the processing unless there are compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

You can also object to any processing related to prospecting without it being necessary to invoke reasons relating to your particular situation.

8.2 – The exercise of rights

The exercise of the rights is carried out by sending an email to the address or by post to the Personal Data Protection Officer, accompanied by any means to establish your identity at the address:

GreenCom Networks AG
Data Protection Officer
St.-Martin-Str. 63
81669 Munich

The communication of specific post-mortem directives and the exercise of rights are carried out by post, accompanied by any means to establish your identity, to the Personal Data Protection Officer, at the address:

GreenCom Networks AG
Data Protection Officer
St.-Martin-Str. 63
81669 Munich

8.3 – Withdrawal of consent

You can also withdraw your consent at any time, in cases where it has been requested (the withdrawal of your consent will not affect the lawfulness of the processing carried out before the withdrawal of consent).

8.4 – Lodging a complaint

If you consider, after contacting us, that your rights over your data are not respected, you can send a complaint to the Bavarian State Commissioner for Data Protection.