Linde Data Protection Hub
1. General Privacy Notices for Websites, Business Partners, Clients & Suppliers
Privacy Notice by Linde entity (in local language)
North America
South America
Brazil
Chile
Colombia
Ecuador
Paraguay
Peru
Uruguay
EU Countries / EEC Linde Gas
Austria
Linde Gas
Linde Healthcare Webshop
Belgium
Cyprus
Czech Republic
Germany
Linde Gas
Linde Healthcare Elementar
Denmark
Estonia
Finland
France
Linde Gas
Linde Healthcare
Linde Homecare
Greece
Hungary
Iceland
Ireland
Italy
Latvia
Lithuania
Netherlands
Linde Gas
Linde Healthcare
OCAP
Norway
Poland
Portugal
Romania
Slovakia
Spain
Sweden
Switzerland
United Kingdom
EU Countries / EEC Linde Engineering
Africa
Asia
Bangladesh
China
Hong Kong
India
Linde South Asia Services
Linde Gas
Praxair
Indonesia
Kazakhstan
Kuwait
Philippines
Saudi Arabia
Singapore
South Korea
Sri Lanka
Thailand
United Arab Emirates
Vietnam
2. Applicant Privacy Notices
See your local Privacy Notice for details on how your personal data is processed during recruitment.
Countries
Austria
Austria - Linde Electronics GmbH (Deutsch)
Austria - Linde Electronics GmbH (English)
Austria - Linde Gas GmbH (Deutsch)
Austria - Linde Gas GmbH (English)
Austria - Linde Hydrogen FuelTech GmbH (Deutsch)
Austria - Linde Hydrogen FuelTech GmbH (English)
Austria - Linde Österreich Holding GmbH (Deutsch)
Austria - Linde Österreich Holding GmbH (English)
Bahrain
Belgium
Cyprus
Denmark
Finland
France
Germany
Greece
Hungary
India
Ireland
Italy
Mexico
Norway
South Africa
Spain
Sri Lanka
Sweden
Switzerland
United Kingdom
United States
United States - Download a notice describing federal equal employment opportunity laws
United States - EEO is the Law OFCCP Supplement
United States - Linde's Equal Employment Opportunity Policy
United States - OFCCP Pay Transparency Statement
United States - Notice at Collection and Privacy Policy for California Job Applicants
United States - Workplace Accommodations
United States - Information for Applicants on US jobs
3. Pensioners Privacy Notices
See your local Privacy Notice, where applicable for select pensioners, for details on how personal data is processed by Linde.
Countries
Ireland
United Kingdom
4. Privacy Notices & Terms of Use for Linde's Microsoft Office 365 Platform (External Users & Guests)
General Privacy Notice for External Users Accessing Linde's Office 365 Platform
From time to time, it may be necessary to adapt this notice to comply with legal requirements or to cover new or modified services. The most recent version of this data privacy notice can be found at: https://dataprotection.linde.com/
1. Controller and Data Protection Officer
The controller for the processing of your personal data on Linde’s Office 365 platform is Linde GmbH Dr.-Carl-von-Linde-Strasse 6-14, 82049 Pullach, Germany. Linde GmbH is a subsidiary of Linde plc (in this document, Linde plc and its affiliated companies are referred to as “Linde”), a leading global industrial gases and engineering company. Linde’s Office 365 platform includes Teams, Sharepoint and other services included in Microsoft Office365 that are made available to you.
Contact details of the EU Group Data Protection Officer (“EU GDPO”) of Linde GmbH: Linde GmbH, EU Group Data Protection Officer, Dr.-Carl-von-Linde-Strasse 6-14, 82049 Pullach, Germany, Email: dataprotection@linde.com.
2. Processing of personal data in the context of external access to Linde’s Office 365 platform
The Office 365 platform offers you a variety of functions for searching and communicating with employees of Linde and its external partners (“users”) for business purposes in the form of contributions, comments, likes, follows, and user mentions (@) as well as through the option to share and mark content and documents (“activities”).
We process your personal data in order to provide the functions on the platform. The type, scope, and purpose of processing personal data depend on your activities on the platform and are defined by the business relationship between Linde and you or your employer. In any case, your personal data is processed only in accordance with applicable law.
Your activities and related data are visible to other members of your Sharepoint Online / Teams / Team Sites as well as to administrators of the Office 365 platform
3. Type and Origin of Personal Data processed by Linde GmbH
You decide which personal data you share on the Office 365 platform in the form of contributions, comments, likes, follows, and user mentions (@) as well as by creating content using Office 365, such as text typed in a Teams chat or a Word document, or through sharing and marking content and documents (“activities”).
When using the platform, required service data, including data sent by your browser (IP address, cookies, related websites, time and data, content displayed), is used to enable Microsoft (as the platform provider) to deliver the service (i.e. Office 365, MS Teams) and help to make the service secure and perform as expected. Required service data also includes the account being used to connect to our services.
4. Purpose for Processing by Linde GmbH and Legal Basis
4.1 We process Data to fulfil our Contractual Obligations
We process personal data only to the extent necessary to fulfil contractual and legal obligations in connection with the business relationship with our customers, suppliers and partners. The purpose of use of Linde’s Office 365 platform is defined by the business relationship between Linde and you or your employer.
4.2 We process Data to protect Legitimate Interests
We also process personal data insofar as it is necessary to safeguard the legitimate interests of Linde GmbH 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. This is the case where data is generated by your activities in relation to work results in a business relationship between Linde and your employer, but also for example in relation to maintenance and support of the Office 365 platform operation including security measures and related audits.
5. Recipients of your Data
In order to provide the platform and to ensure lawful use, administrators working on our behalf have access to all activities and other information. These administrators may be employees of any global Linde companies or third parties commissioned by Linde to process data. In the event of a technical fault – in exceptional cases – platform administrators of Microsoft must also temporarily be granted access to the data. These other Linde companies or third parties are acting as processors on behalf of Linde GmbH.
6. Transfer to Third Party Countries or International Organizations
We may transfer personal data to recipients with an adequate level of data protection. Linde GmbH has taken and will take appropriate measures to ensure an adequate level of data protection at the recipient, in particular by relying on adequacy decisions of the EU Commission or Standard Contractual Clauses issued by the EU Commission. More information on these measures is available via the EU Group Data Protection Officer.
7. Storage and Retention Periods
We process personal data relating to “activities” or included or related to content and documents (including user account data) as long as it is necessary for the fulfilment of the business relationship with you or your employer. As soon as the data concerned is no longer required for this, it is generally deleted, subject to applicable retention periods.
8. Automated Decision-Making and 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.
9. Your Data Privacy Rights
All data subjects have the following rights pursuant to Articles 15 to 21 GDPR - within the statutory limits of the EU member states:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
You have the right to object at any time to certain types of processing of your data for reasons arising from your particular situation. This right only applies to data processing in the public interest and to data processing based on legitimate interests. You may also object to profiling, insofar as it is based on these two provisions. If you object, we will cease processing your personal data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Your objection does not require any specific form and can be e-mailed to us at: info@linde.com
You also have the right to file a complaint with the competent supervisory authority (see Art. 77 GDPR).
Pullach, February 2021
Supplementary Linde Office 365 Privacy Notice for Teams Recording, Transcription & AI-related Features
This privacy notice governs processing of personal data when approved Microsoft Teams recording, transcription, attendance, accessibility or AI-assisted meeting features are used for Linde business.
It serves as a global notice, in line with European Union General Data Protection Regulation requirements and applies only to features enabled for the relevant country, entity, population and approved use case. Organizers, co-organizers or initiators of meeting transcription and recording features, may also provide additional meeting-specific information.
1. Who is Responsible?
Central tenant/service governance and centrally commissioned activities
Controller: Linde GmbH & select Linde plc affiliate entities
Identification / contact: Linde GmbH - Dr.-Carl-von-Linde-Straße 6 - 14, Pullach, 82049, Germany
Local business use
Controller: All Linde plc affiliate entities employing meeting organizers & authorized participants who initiate features covered by this privacy notice.
Identification / contact: Refer to the Linde entity employing the Meeting Organizer and/or initiator of recording and/or transcription.
Note: Linde plc affiliates may act as joint controllers for the above processing activities in select cases under applicable laws
2. Data Protection Officer & Privacy Contacts
For global and EU/EEA-related questions and enquiries, contact the Linde corporate privacy team and the EU Group Data Protection Officer at Linde GmbH, Dr.-Carl-von-Linde-Strasse 6-14, 82049 Pullach, Germany, dataprotection@linde.com, and your message will be relayed to the appropriate Linde contact for your region
3. Features & Purposes
Features and approved purposes under this Privacy Notice may include any of those listed below. Meeting organizers or initiators of the features will determine and inform you of which purpose(s) apply in their meeting, ensure these are not prohibited under Linde’s Terms of Use or any supplementary requirements.
Recording, Transcription & Attribution Features - Permissible purposes:
- Allow participants to document meetings, decisions & activities.
- Support impaired users
- Facilitate language barriers
- Enable absent participants to catch up.
- Training & knowledge sharing/management.
- Information retrieval & searchability.
- Central tenant/service governance (Linde-authorized IT personnel only)
- Security, Regulatory, legal or audit requirements (Linde-authorized IT, audit & legal personnel only)
Status: Features are off by default & may be switched on/off by select participants.
AI-supported Recap / Summary / Accessibility Features - Permissible purposes:
- Generate meeting summaries & recaps.
- Identify key points, decisions & follow-up actions.
- Support productivity, reduce manual note-taking.
- Support information retrieval/knowledge capture.
Status: Feature is allowed by default for select Linde users, subject to user activation. Note Microsoft Copilot may be used during a Teams meeting with or without transcription, depending on the applicable meeting settings. Where Copilot is used without transcription, meeting audio is processed using temporary speech-to-text data to generate AI responses, but that speech-to-text data is not saved after the meeting. Where transcription is activated, Copilot may use the resulting transcript and can remain available for permitted post-meeting use. Copilot prompts and responses may be retained in accordance with retention policies as described at section 9.
Subject to any exceptional use for compliance, investigations, legal proceedings, or disciplinary matters, which must comply with applicable law, internal requirements, works council arrangements, employee representative obligations, and data protection requirements, Linde does not use any features described in this section for the purposes of:
- continuous employee monitoring;
- behavioral profiling;
- productivity scoring; or
- employee-surveillance activities.
4. Personal Data Processed
Personal data processed under this Privacy Notice may include the categories listed below:
Recording of audio or video content
- Examples: Voice, camera stream, screen and audible/visible content
- When processed: When activated
Transcription
- Examples: File, transcript text, timestamps, speaker attribution
- When processed: When activated
Participant / meeting metadata
- Examples: Names, identifiers, invitation, attendance, title, date/time, organizer
- When processed: Generated by meeting / feature
Permitted AI inputs / outputs
- Examples: Transcript/chat/content/metadata; recaps, summaries, action items
- When processed: When underlying transcription is activated – for Copilot users.
Sensitive / 3rd party data
- Examples: Special-category, privileged or confidential information
- When processed: Not sought. Processing such data should be validated by externals & meeting organizers in advance of meeting.
5. Purposes & Legal Bases
Legal Bases for Meeting organizers or, where different, the initiators of any recording and/or transcription features:
- All must ensure they have a lawful basis to process personal data, considering the purposes determined under section 3, and the laws applicable to each individual participating in the meeting, including by ensuring, where required, that all participants have given their explicit consent before the recording or transcription begins.
- If applicable requirements are not satisfied, recording or transcription must not take place. Where consent is not a valid legal basis and an alternative legal basis applies, the recording may only proceed if all associated requirements are met.
Legal bases for centrally governed activities:
- Where, in the performance of central tenant/service governance activities for Linde plc affiliates, transcription and/or recording-related personal data may incidentally processed by Linde GmbH and any of its processors in accordance with applicable laws.
- Where, in the performance of any centrally commissioned legal, compliance or security activities, by any Linde plc affiliates, to address any regulatory, legal, security or audit requirements, transcription and/or recording-related personal data is processed, the lawful basis shall be to comply with a legal obligation as mandated by law, or to protect Linde plc and any of its affiliates' legitimate interests, including for the establishment, exercise or defense of legal claims, or as may be established under applicable law in consultation with Linde corporate compliance.
6. AI-assisted Meeting Safeguards
For each AI feature associated with transcription and recording and identified below:
- AI-generated outputs are intended to assist users and may contain inaccuracies, omissions or incorrect attributions.
- AI outputs will not be used to make solely automated decisions producing legal or similarly significant effects, unless permitted by applicable law.
- Data processed through Microsoft 365 Teams recordings, transcripts, AI recaps and summaries, is not used to train foundation AI models shared across Microsoft customers and is subject to Microsoft 365’s customer data protection, contractual commitments and tenant-level controls.
AI Meeting Recap
- Inputs may include: Meeting transcript; meeting metadata (participants, organizer, date/time); recording content where enabled; meeting chat and shared content if supported by the feature and license configuration.
- Outputs may include: AI-generated recap, key discussion points, speaker-attributed references, chapters/topics, timeline markers, suggested action items & related meeting insights.
Meeting Summaries
- Inputs may include: Meeting transcript; meeting metadata; meeting chat; meeting content made available to the summarization feature.
- Outputs may include: Concise meeting summary; key points; decisions; follow-up items; identified actions and tasks.
Searchable Transcripts
- Inputs may include: Spoken meeting audio converted into text through transcription; speaker attribution where enabled; timestamps and meeting metadata.
- Outputs may include: Searchable transcript text; speaker-attributed transcript entries; timestamps; transcript exports if permitted by policy.
Action Items / Task Extraction (only premium Copilot users)
- Inputs may include: Transcript content; meeting summary content; meeting metadata; discussion context available to the feature.
- Outputs may include: Suggested action items; task descriptions; possible owners; follow-up recommendations.
Speaker Attribution
- Inputs may include: Transcript text; voice/audio information; participant identity and meeting participation metadata.
- Outputs may include: Identification of speakers within transcript and recap outputs; attribution of statements to participants.
7. Data Recipients & Access Groups
The following recipients may have access in accordance with their authorized processing purposes and reasons listed below.
- Organizer, co-organizer & authorized participants - Reason for access: Meeting participation & post-meeting access in line with permitted purposes.
- Team or channel members, where stored or shared there - Reason for access: Meeting participation & post-meeting access in line with permitted purposes.
- Authorized IT Support Personnel, Security, Compliance, Legal and Audit Teams - Reason for access: Central Tenant Support & Administration, Security & Compliance Administration, Specific authorized tasks, case controls & investigations
- Microsoft & approved support providers - Reason for access: Provide approved support
- Authorities, regulators, courts - Reason for access: Lawful request or legal claims
8. International Transfers
Personal data may be processed outside the country of collection by default as listed below. Any additional international data transfers may occur due to meeting and user specifics, and are under users’ responsibility.
Microsoft hosting, operations or support
- Destination: All transcripts, recordings and AI-related output are hosted by default in Ireland & secondary data centers in the European Union.
- Mechanism and supplementary measures: For EU/EEA: Not applicable for hosting. Support services may only involve processing as agreed contractually with Microsoft (e.g., EU Standard Contractual Clauses and/or adequacy decisions).
Intra-group remote access for central tenant support & administration
- Destination: Select Linde plc affiliate entities, including in Sweden, Slovakia, India & United States.
- Mechanism and supplementary measures: EU Standard Contractual Clauses, where required.
Intra-group remote access for legal & audit activities
- Destination: Select Linde plc affiliate entities, including in the United States and Germany.
- Mechanism and supplementary measures: EU Standard Contractual Clauses, where required.
Intra-group access for security & compliance activities
- Destination: Select Linde plc affiliate entities, including in the United Kingdom, India & United States.
- Mechanism and supplementary measures: EU Standard Contractual Clauses, where required.
Approved service providers
- Destination: Romania and India
- Mechanism and supplementary measures: EU Standard Contractual Clauses, where required.
9. Retention & Deletion
Recording & Transcription: All are stored by default in an organizer’s OneDrive, or where applicable, in the SharePoint associated with the Teams Channel, are subject to a default 30-day retention period, an additional recycle bin recovery period, and any superseding legal hold or compliance requirements.
Consult your meeting organizer for details.
CoPilot AI recap / summary / action items: Applicable to Copilot license holders only - There is currently no centrally defined global default retention period for AI summaries, prompts and responses. Retention & deletion rules are deferred to meeting organizers and their regional business units or segments. Consult your meeting organizer for details.
Any deviating retention and deletion periods applicable to meeting artifacts may be determined by users of the M365 Teams Meeting features covered by this Privacy Notice, in accordance with applicable laws, retention schedules and Linde Terms of Use.
10. Security & Confidentiality
Personal data processed under this privacy notice is subject to adequate technical and organizational measures, as determined by Linde Corporate IT.
11. Your Choices & Rights
Subject to applicable laws, conditions and limitations, the following rights may apply with respect to your personal data:
- Request access to, correct, delete, export, or restrict the processing of your personal data under this Privacy Notice;
- Request an alternative to transcription & recording features, where consent is required or legitimate interest applies;
- Withdraw your consent for future processing, where consent is used;
- Object, where applicable, to a meeting organizer's legitimate interests where relied upon as lawful basis
Submit your requests to your meeting organizer or the initiator of the relevant features, as applicable.
Any individuals' rights requests under this Privacy Notice, where not be addressed by the meeting organizer and/or initiator, may be sent to dataprotection@linde.com who may support with forwarding the request to the appropriate service owner.
You may have a right to submit any complaint to your supervisory authority under your applicable laws.
12. Changes or Supplements to this Privacy Notice
- Any material changes shall be reflected in this Privacy Notice and communicated before taking effect where required.
- This privacy notice shall be reviewed periodically.
- Linde regional and business segments or Linde meeting organizers or participants may supplement this policy as required to comply with their applicable requirements.
Microsoft Office 365 - Terms of Use for Guests (3rd Parties)
Information Protection
The 3rd party agrees that any information and data exchanged is the property of Linde and must be handled in accordance with applicable laws, regulations and contractual obligations, in particular - in case of personal data (personal identifiable information - in accordance with applicable data protection / privacy laws and thus in a confidential manner. The information and data shared with the 3rd party in Office 365 applications must not be shared outside of its intended use and the defined purpose and must be done in consideration of a confidentiality agreement, a data sharing agreement and/or, if applicable, a data protection agreement such as a data processing agreement (DPA) or data transfer agreement (i e EU Standard Contractual Clauses – EU SCC) between the third party and Linde.
We expect our connected guests to operate their (mobile) devices in a secure and compliant way and to regularly update their device OS and apps. In case the device OS or app used for access is determined to be vulnerable or any unusual activity leads to a suspicion of compromise, Linde reserves the right to block access to shared data or resources without undue delay and without prior notice. Additionally, bulk or automated download of shared data is prohibited.
Pullach, February 2021