Privacy Statement

GE Trade Payables Services Privacy Notice

May 2018

GE Capital Trade Payables Services, LLC and its group affiliated entities (collectively, the "TPS Group"), respect your concerns about privacy. References in this Privacy Notice to "TPS", "we", "us", and "our" are references to an entity within the TPS Group that is responsible for the processing of your personal information.

This notice ("Notice") describes how we, as Data Controller, will handle, share and protect personal information that you provide, or which we obtain about you.

1. What does this Notice Cover?

This Notice applies to the personal information we obtain from General Electric Company and its subsidiaries and affiliates in connection with the financial services we provide to such entities.

This Notice describes the types of personal information we obtain, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Notice also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

This Notice is limited to TPS and does not apply to personal information obtained through other GE channel websites such as our careers website, which is subject to the Candidate Privacy Notice available at www.GE.com.

2. What information does TPS collect about me?

We may obtain personal information through the various channels described above. The types of personal information we may obtain include:

  • contact information (such as name, phone, address, email, ID number) for you;

  • bank account information (Bank name, number, account, currency and IBAN);

Please note that providing personal information to General Electric company and its subsidiaries and affiliates is voluntary on your part.

By providing us with personal information you confirm that you have reviewed this Notice and agree to its processing as explained herein.

Cookies and Similar Technologies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. We use cookies only to enable security functionality. However, we do not use cookies to track visitor behaviours.

This portal does not automatically capture or store personal information, other than the userís IP address which can be used to analyse visitors to the portal.

Other websites

Our website may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by us. We are not responsible for the privacy practices of third parties, which are subject to their respective privacy policies.

3. How does TPS use my personal data?

We may use the personal information we obtain to:

  • provide and administer our products and services;

  • [FA(C1] perform data analytics (trend analysis, financial analysis and customer segmentation);

  • provide supplier support, including relating to complaints and data access requests;

  • operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; managing our communications and supplier relationships; and performing accounting, auditing, billing, reconciliation and collection activities);

  • verify your identity and protect against and prevent fraud and other unlawful activity and unauthorized transactions; [FA(C2] [FA(C3]

  • conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and

  • maintain and enhance the safety and security of our products, services, network services, information resources and employees.

We may combine personal information we obtain through various channels for the purposes described above. We may anonymise or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law[FA(C4] . We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

The legal basis for us processing your personal information, as described above, will typically be one of the following:

    • for the performance of a contract with you or a relevant party;

    • to fulfil our legitimate business interests;

    • to comply with our legal obligations; or

    • on the basis of your consent.

We will not use your personal information for marketing purposes; should this position change in the future we will contact you to obtain your consent to receive marketing information from us.

4. Who does TPS share data with, or transfer data to?

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

  • We may share personal information within the TPS Group and that of our parent companies within the GE Group for the purposes described in this Notice.

  • We may share personal information with service providers we have retained to perform services on our behalf. These service providers are contractually required to safeguard the information and are restricted from using or disclosing the information provided to them except as necessary to perform services on our behalf or to comply with legal requirements.

  • We may disclose your information to external funding partner for the purposes described in this Notice;

  • We may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

We reserve the right to transfer any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganisation, divestiture, dissolution or liquidation). In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.

5. How does TPS protect my data?

We maintain administrative, technical and physical safeguards, consistent with legal requirements, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us.

Wherever we share personal information we will exercise measures to safeguard it and ensure it is only processed as strictly necessary to fulfil a contractual task or legal obligation.

We may transfer the personal information we collect to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Notice. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information. The GE Group has entered into Binding Corporate Rules governing our handling of personal information of residents of the European Union. For further information about the GE Groupís Binding Corporate Rules, please refer to this link: https://www.ge.com/bcr

6. How long is my data retained for?

Your personal data is retained in accordance with our Data Retention Policy, which is designed to make sure data is kept for no longer than necessary, and is disposed of where there is no longer a valid reason for the data to be retained.

Data retention periods are determined by taking into account legal limitation of liability periods, agreed contractual provisions, applicable regulatory requirements and industry standards.

7. What are my rights?

You have a number of rights available to you when it comes to the processing of your personal data.

Data Access

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email WCS_privacy@ge.com.

We will not charge you for this service. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

Data Rectification

We want to make sure that your personal information is accurate and up to date. If you believe the personal data we hold about you is inaccurate you have the right to challenge it. You may ask us to update, correct or erase information you think is inaccurate.

Data Erasure / Objection to processing

You have the right to request your personal data to be deleted or alternatively object to your personal data being processed in certain circumstances. You may ask us to delete or cease to process your data and we will assess your request.

The data held by us is important to ensure compliance with our legal and regulatory obligations or our legitimate interests as a responsible lender, preventing fraud and money laundering, compliance with contractual provisions, and legal liability limitation periods. It will be rare that we do not have compelling, overriding grounds to carry on using the personal data following an objection or request for erasure.

Restriction of Processing

You have the right to request we restrict how we use your personal data. The right is not absolute and we may still continue to process your personal data where certain grounds are established:

  • With your consent;

  • For the establishment, exercise, or defence of legal claims

  • For the protection of the rights of another natural or legal person;

  • For reasons of important public interest.

Data Portability

You have the right to receive a copy of your personal data in a structured, commonly used format, and to have your data transmitted to another controller where we are processing such data for the purposes of performance of a contract, or with your consent.

This right does not apply where we are processing data for other purposes, such as for compliance with a legal obligation or for another legitimate interest.

8. How do I make a complaint?

If you have a complaint regarding our processing of your personal data, please email WCS_privacy@ge.com.

We will respond to your complaint within 30 days. If you are not satisfied with our response you may have the right to file a complaint with a supervisory authority or other governmental regulator.

9. How do I withdraw consent?

If your provided your consent to us processing your personal data, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate.

It is important to note that data provided to us by you is largely processed for the performance of a contract, for adherence to legal requirements and for other legitimate interests. There may be limited instances where we process data based solely on your consent and as such we may not be able to comply with any request to cease to process this data.

You may submit an application to withdraw consent by email at WCS_privacy@ge.com.

10. Does TPS use automated decision making?

We do not use personal data provided by you for automated decision making or profiling activities.

11. How do I contact TPS?

You have the right to request access to the Personal Data that we process about you and to ask us to delete them from our records or to correct them. If you wish to make such a request, or if you have any feedback for us concerning our Privacy Policy, please contact us at the following email address: WCS_privacy@ge.com Ė we aim to respond to your query within one month.

Changes to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Notice when it was most recently updated.