1. Personal data operator  

The operator of the personal data obtained from or granted by the company’s clients is:  

Pramra Global Resources GmbH (hereinafter called “Pramra Global”)

Registered office address: Marxergasse Street no. 24/2, 6th floor, room 2:2, 1030 Vienna, Austria; 

You can contact us through:

E-mail: customercare@pramraglobal.com

By post mail: up mentioned address.  

2. Requests regarding the Personal Data Storage (Retention) Policy 

This Policy is applicable to both our contractual partners as Personal Data Operators and/or Data Processors under the General Data Protection Regulation and individuals with whom we are directly in contact for processing an order and any activity that is part of or in connection to products you buy form our Website.

We only store and process your personal data in cases where you have voluntarily provided these data by sending a message using the predefined contact form on the website, telephone, e-mail or in direct contact with you or through our subcontractors, if the case.

To the extent that you have a request or a question about the periods of storage of your personal data within Pramra Global, please contact us using the above-mentioned email address.

3. Storage Policy 

The Pramra Global storage policy is a tool that ensures requirements regarding the principle of accuracy and storage limitation of personal data under the General Data Protection (GDPR), relevant laws and regulations in the field of personal data protection are strictly undertaken by our company. This policy encompasses the principle of limiting the time frame for retention of personal data which has been processed, which requires storage only for the time required for purposes for which such data is processed. The personal data retention (storage) policy is primarily intended as a favourable resource to the company’s activity that will allocate relevant retention periods in important business areas and company departments where the law does not impose precise storage deadlines, allowing the personal data removal/deletion activities to take place in a consistent and controlled manner.

4. Requests regarding the Personal Data Retention (storage) Policy 

The present Policy is applicable to individuals as customers of Pramra Global Resources, legal entities as customers but also to the representatives of our contractual partners, both as Personal Data Operators in relation to Pramra Global Resources or as Data Processors according to the General Data Protection Regulation. We store and process personal data only in cases where you have voluntarily provided us with this data, such as by filling in a contract form, by subscribing to the company’s newsletter or by creating an account. 

If you have any requests of questions regarding the periods of storage of your personal data within our company, please contact us by using the e-mail address or telephone number mentioned above. 

5. Reasons for long-term storage of personal data in Pramra Global Resources

We don’t intend to adopt a “save everything” approach. We consider that such a rule is not practical or cost- effective and would be an excessive burden for all company staff and especially for the IT department which would manage an increasing amount of data. 

However, certain data must be kept for a long time, in order to protect the interests of data subjects, to save any evidence or record of the processing or deletion proceedings according to the law and internal corporate procedures, if we consider that it is necessary and in general, to comply with good business practices. 

Some of the most important reasons for long-term storage of data in our company are the following: 

• Complaints regarding the quality of our products and/or services;
• Litigation;
• Investigation of work-related (professional) accidents;
• Investigation regarding the occurrence of a security incident (cyber-attack or cyber-threat as well as records of any data breach);
• Protection of our intellectual property. 

6. Retention (storage) periods

The personal data storage periods are specified in the table below and apply to all formats of entries, i.e. both paper and electronic format, unless otherwise specified in this Policy. All retention periods may be subject to changes considering the national (local) law of different countries in which Pramra Global operates. 

DEPARTMENT	PROCESSING ACTIVITIES	RETENTION PERIOD
MARKETING	Promotional campaign forms or related campaign documents stored in physical format if the case	3 months after they are stored in a digital format
MARKETING	Electronic campaign forms	3 years as of the date the document is considered final and applicable
MARKETING	Documents certifying winnings or prizes awarded in the basis of competitors and draws	10 years as of the ending date of the respective contest
MARKETING	Customer Support phone calls in relation to the customers	30 days except for calls we need to keep for longer, but no more than 3 years as of the last call. Before the 3-year term, the records of the calls will be deleted or anonymized.
MARKETING	Other information which are not considered personal data, about your participation in a contest if you won a prize	5 years as of the ending date of the contest
MARKETING	Information about participating in campaigns organized on the company’s pages on social networks	2 years of the ending of the respective campaign
CUSTOMER SUPPORT	e-mail or post mail sent by a customer with a claim regarding our products and services or regarding our partners	3 years as of the receiving date of the respective claim irrespective of the format (paper of electronic)
CUSTOMER SUPPORT	e-mail or post mail sent by a customer with a claim regarding the commercial activity of the company	3 years as of the receiving date of the respective claim irrespective of the format (paper of electronic)
CUSTOMER SUPPORT	Data protection request sent by e-mail or post mail by our client	3 years as of the receiving date of the respective claim irrespective of the format (paper of electronic)
CUSTOMER SUPPORT	CUSTOMER SUPPORT	All data/information will be deleted every 3 years, except of specific information and/or data protection which we need to store according to the law.
LOGISTICS	AWB (Airway Bill) and other documents relevant for the shipment (delivery) from our logistic center(s) to our customers	5 years
LOGISTICS	Shipping manifest (NIR)	5 years
NOTIFICATIONS SENT BY PRAMRA GLOBAL	Notifications SENT by PRAMRA GLOBAL directly or through its contractual partners (invoices, notice of non-payment, etc.)	3 years from the date of transmission of each notification
RELATIONS WITH SUPPLIERS	Contracts concluded by the company with suppliers	10 years from the date of contract’s termination
RELATIONS WITH CONTRACTUAL PARTNERS	Service Contracts (undertaking)	10 years from the date of contract’s termination
RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS	Phone calls	We do not record / store phone calls
RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS	Business cards collected at organized events	1 year from the date of receipt of the business card, if the contract is no longer valid
BUSINESS RELATIONS (B2B)	Personal data such as: name, position, and contact details of the representatives of the companies we collaborate with	Until the date requested for the deletion of the data or the date, we have learned that the data became inactive

 

For information on the storage periods of personal data processing activities within the company that are not covered by this Policy, please send your requests to this email address customercare@pramraglobal.com or by accessing other means of communication made available on the Website and having regard to the conditions stipulated in art. 2.

7. Retention plan 

The above-mentioned table containing the recommended timeframe of storing information and/or personal data of customers in the company’s records (systems or physical archives), is provided for each relevant processing activity. The storage period is applied by default to all entries in that category and will be complied with whenever possible, although we admit that there may be exceptional circumstances requiring the retention of documents for either shorter or longer periods. If entries or individual documents require a different retention period, Pramra Global should be contacted to discuss and settle specific storage requirements.

8. Data deletion  

You may request the deletion of personal data to the extent that we hold these data at the time of submitting the request by sending an email to customercare@pramraglobal.com in which you need to specify the following: 

– Your contact details for sending the company’s response / opinion; 

– Your name; 

– Processing activities through which data was collected or processed (in promotional campaigns such as events, prize competitions or other types of campaigns for marketing and advertising purposes, the conclusion of a contract, the transmission of a written request by post or e-mail or by phone call, etc.);

– The type of collected or processed data that you want to delete; 

– Total number of entries to be deleted.

If we no longer have personal data obtained from you after a direct contact with you at the time of your request, but a partner of ours still holds your data, we will provide you with the information details of our partner’s data in order to address your request. Please take into consideration that our partner’s policies and practices will apply in relation to you and we take no responsibility for the outcome of your request. Furthermore, we respond to deletion requests we might receive from representatives of our contractual partners.

The deadline for replying to the request is one month (30 days) after the request was submitted. We will try our best to provide you with an answer of a solution as fast as reasonably possible. 

To the extent that your request will be solved after our assessment, with the deletion of your data, we will prepare a standardized document which we will send to you through the agreed means of communication. 

The document shall include at least the following information:

– The purpose on which a specific data was obtained (processed); 

– information and/or personal data that was transferred/deleted/removed/destroyed, and the processing activity performed within Pramra Global; 

– Number of entries removed.  

The hardcopy transmitted is signed by a representative of Pramra Global and is stored and scanned in a physical format for a 3 years term as of the date receiving date of your request. After this period, the original document will be destroyed and recycled. If we will send our response by email, that e-mail will be stored in the company’s e-mail servers for a period of 3 years as of the submission date and afterwards we will delete it. 

If you submit a request to Pramra Global asking to access personal data that belongs to you and that we processed, please be aware that due to the ongoing processing of your personal data and taking into account the routine established in our systems for deleting processed information (according to the terms of this Policy), we try to keep your data up-to-date and accurate at all times. Thus, this routine processing may involve deleting or anonymizing the personal information we process after you have submitted a request to us. In this case, Pramra Global will provide a response applicable for the information held at the time we send you the response, even if the information is different from the information we stored at the date you sent your request to us. Please note that deleting or anonymizing your personal data is a procedure that Pramra Global would have performed even if you had not submitted the request. 

9. Continuous development 

The storage (retention) periods will be updated by Pramra Global, modifications and updates being necessary from time to time, as well as any additions, whenever the applicable legislation, the guidelines of the Data Protection Authority from the countries we operate or, the organizational or internal IT infrastructure modifications/updates impose these changes.

10. Updates

Our data storage (retention) policy may be changed or updated from time to time (generally to comply with data protection and processing laws and practices). Updated versions will be published on our Website.

Version: August / 2020