Last updated: June 14, 2024

Please note the following Statement is intended for Linde plc in accordance with General Data Protection Regulation (“GDPR” – EU Regulation 2016/679) requirements and the laws of Ireland.

1. Who we are

With the following data privacy notice, we would like to inform you about the processing of your personal data by Linde GmbH (hereinafter also referred to as “Linde”).

From time to time, it may be necessary to adapt this privacy policy as whole as well as specific parts of it to comply with legal requirements or to cover changed or additional processing activities.

1.1. Controller

The controller responsible for processing of your personal data in the sense of data protection law is Linde GmbH.

1.2. Data Protection Office

The contact details of the Data Protection Office of Linde GmbH are:

Linde GmbH
Legal & Compliance Department
Dr.-Carl-von-Linde-Strasse 6-14, 82049 Pullach, Germany
Email: dataprotection@linde.com

2. What data we will process

2.1. For the purposes of the Linde Virtual Academy Express in the Meta app store

When you use the Linde Virtual Academy Express (or any other application designed for VR training purposes on the Meta Quest) of Linde GmbH, we collect certain personal data from you, which may include your name or email address. Such data is typically actively provided by you when you use our application(s).

The following data (in particular log information and device data) is automatically processed by the application.

• Your Name and email address (if provided)
• Date, duration and time of your usage of the application
• Your interactions with objects within the application and the time between the interaction

Your log data may be used for analytical purposes to improve our application functionality and performance. This data shall help to identify relevant features of the application which might be relevant for future updates.

2.2 For core business purposes

If you decide to get into a business relationship or actively subscribe to our Linde E-Mail newsletter will process personal data processed for core business purposes includes. This might include

• Master and contact data of customers and suppliers, such as name, address, telephone number, e-mail address, function, department of our contact persons, etc.

We regularly receive the personal data processed by us within the framework of and in the course of our business relationship with our customers. In some cases, we also receive personal data from affiliated companies of Linde, e.g. contact data from suppliers within Linde’s supplier relationship management.

In some cases, we also process personal data that we have received in another manner, in accordance with the applicable data protection laws. This is regularly the case regarding:

• Publicly accessible sources, e.g. trade and business registers, trade fairs, exhibitions, Internet sources, newspapers, trade directories, etc.
• Third parties who are not affiliated with Linde GmbH, e.g. trade/business associations, credit agencies, insurance companies, etc.

3. Why we will process your personal data & Legal basis

We process your personal data for permitted purposes and in accordance with the applicable legal provisions of the GDPR and relevant national data protection laws.

3.1. Application in the meta store

When you use the application of Linde GmbH, the personal data we collect from you shall be processed in connection with the operation of the application and is typically actively provided by you when you install / use the application or sign up for receiving additional information regarding our services.

The purpose of the LVA-Express application on the Meta Quest VR headsets is to allow potential Clients of Linde GmbH to experience a virtual reality experience. Linde GmbH is offering the development of virtual reality training courses. LVA-Express is a dedicated application that shall provide and overview of the potential of VR in training applications specifically developed for the gas processing business.

3.2. Core business purposes

We process personal data to the extent necessary to fulfill our contractual and legal obligations in connection with the business relationship with our customers, suppliers and partners. “Processing” means that we collect, store, delete or transfer personal data, to list a few examples.

 3.3. Legal bases of processing

3.3.1. We process Data to protect Legitimate Interests

We process personal data insofar as it is necessary to safeguard the legitimate interests of Linde or Linde companies as well as our customers (and, if applicable, other third parties). Where this is the case, we process personal data only after due consideration of your relevant interests.

3.3.2. We process Data with your Consent

We process your personal data in cases where you have given us your consent. You may revoke your consent at any time. Please note, however, that data processing up to the date of revocation remains permissible. This may include alert registrations or measures to analyze pseudonymized user behavior to further improve our websites.

3.3.3. We process Data to fulfill Legal Obligations

We are required to process certain data in order to comply with legal obligations. Such obligations may arise from certain provisions of national commercial, trade, tax and social law as well as European legislation, e.g. in connection with regulations to avoid the financing of terrorism. In detail, this may also result in obligations for Linde to safeguard, store, report and collect data, which generally serve control purposes from the respective authorities.

3.3.4. Information regarding Change of Purpose

Should we process your personal data for any reason other than that for which we originally collected them, we will only do so to the extent permitted by law and will inform you of this new purpose.

3.4 Automated Decision making & profiling

We do not use automated decision-making processes for procedures that have legal implications or a similarly significant impact on you. No decision will be made without further human review.

Profiling within the meaning of Art. 4 (4) GDPR in general does not take place at Linde. In case of an exception, a separate data protection notice will be provided.

4. With whom we will share your personal data

4.1. Data Collected for Core Business and in the Linde Virtual Academy – Express

Personal data will be made available to other companies of Linde GmbH if and insofar as this is necessary for internal administrative purposes. Typical examples are centralized IT services, and communications. We use external service providers as processors who may process personal data only on our behalf and subject to our instructions. This is the case, for example with website analytics, hosting of IT infrastructure or subscription to alert services.

In the context of the continuous development of our business, we may divest subsidiaries or business parts or merge our business or parts thereof with another company. Such transactions typically entail the transfer of customer information pertaining to the sold or divested subsidiary or business part to the buyer or to the company created by the merger.  In the unlikely event of a complete sale of Linde or substantial parts thereof, your personal information will also be transferred to the buyer.

5. Where we transfer your personal data – International Data Transfers

We take care not to transfer your data to recipients in countries without an adequate level of data protection (third countries). However, in some cases, this cannot be completely avoided. Where this is the case, Linde takes appropriate measures to ensure an adequate level of data protection at the recipient. These include in particular adequacy decisions by the EU Commission or standard data protection clauses adopted by the EU Commission which are available via the EU Data Protection Office.

6. Storage – How long we retain & when we delete your personal data

We process personal data only as long as necessary for the purpose of processing. Log files are stored for up to 90 days. However, we may have to store some data for an extended period of time subject to applicable legal requirements or for the establishment, exercise or defense of legal claims.

7. Your Data Subject Rights and how to exercise them

 To exercise any of your rights, please contact vr@linde.com

 7.1. GDPR Data Subject Rights over any processing of personal data by Linde GmbH

Data subjects have the following rights subject to applicable law:

• Right to information
• Right to correction
• Right of deletion
• Right to limitation of processing
• Right to data transferability
• Right of objection

Furthermore, you have the right to revoke your consent to the processing of your personal data at any time with effect for the future. Such revocation has no effect for the past, i.e. it does not affect the legitimacy of the data processing carried out up to the revocation.

If you are of the opinion that the processing of personal data by Linde is not in accordance with the data protection regulations or you are not satisfied with the information provided by us, you have the right to file a complaint with the competent supervisory authority (see Art. 77 GDPR), which for Linde is: Data Protection Commission, 21 Fitzwilliam Square, South Dublin, D02 RD28 RD28, Ireland.

7.2. Objection to processing based on legitimate interests or in the public interest

 You have the right to object at any time to processing of your personal data based on public interest and to data processing based on legitimate interests (Art. 6 para 1 € and (f) GDPR)  for reasons arising from your particular situation. This right also applies to profiling, insofar as it is based on these two provisions. We may continue processing personal data if we have compelling legitimate grounds  which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

In particular, you have the right to object to the processing of your personal data for direct marketing purposes.

8. Cookies and Tracking

The Linde Virtual Academy Express application does not use cookies.

9. Date

 June 14^th, 2024