WEBASTO - Feel the Drive
  • Data Protection Declaration

    The companies of the Webasto Group (Webasto SE, Webasto Roof & Components SE and Webasto Thermo & Comfort SE and their affiliated companies pursuant to Sections 15 et seq. of the German Stock Corporation Act (AktG) respect your privacy and take the protection of personal data very seriously. We would like you to know when we store what data and how we use it. We have taken technical and organizational measures to ensure that the relevant data protection regulations are observed. We process personal data exclusively in accordance with the provisions of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act [Bundesdatenschutzgesetz, BDSG].

      1. Anonymous data collection

        As a general rule, you can visit the non-personalized online magazine Easy Way (https://easyway.site) without telling us who you are. When you visit our website, the IP address currently used by your PC, the browser type and your PC's operating system, the website from which you visited us, the date, time, and websites visited by you are recorded. However, inferences cannot be made based on personal data and are not intended. This information is evaluated for statistical purposes. You remain anonymous as an individual user.

      2. Personal Data 

        Personal data is information relating to your person. This includes information such as your name, address, postal address and telephone number. Furthermore, when you visit our online presence (easyway.site), further usage data is logged such as

        • the IP address,
        • the browser type and operating system of your PC,
        • the website from which you are visiting us, and
        • the date, time and the websites that you have visited.

        Personal data is only collected by the companies of the Webasto Group if it is generated automatically as part of the usage process or if you provide us with this voluntarily, for example when filling out a registration form, registering for personalized services or submitting an application. Your data entered in the form will be stored solely for the following purposes:

        • for Webasto to meet your quotation request
        • to register for the newsletter and to send you the newsletter
        • to forward your data to the relevant HR department in the scope of an application.
        • to analyze anonymized user data for the purpose of expanding and improving our website
      3. Purposes of processing and legal basis

        For the fulfilment of contractual obligations (Article 6(1) lit. b GDPR)

        Your data will be processed on the basis of Article 6(1) lit. b GDPR for the purpose of performing and executing orders and contracts within the scope of the implementation of our contracts with our customers and suppliers or for the purposes of implementing pre-contractual measures which are taken at your request. This includes, in particular, concrete inquiries that we receive at events such as trade fairs. Furthermore, the relevant legal provisions apply to those processing operations that are necessary for us to be able to make our online services available to you.

        The purposes of data processing depend primarily on the specific product and/or service provided and may include, but are not limited to, demand analyses, consultations, purchase contracts and contracts for work and labor as well as regulatory requirements. Further details on data processing purposes can be found in the relevant contract documents and terms and conditions.

        Irrespective of established contractual relationships and your interest in our services, you also enter into a user relationship with us by visiting our online presence. The processing of usage data resulting from the visit of our online presence is also legitimized by Article 6(1) lit. b GDPR.

        (1) Within the scope of the balancing interests (Article 6(1) lit. f GDPR)

        If necessary, we process your data beyond the actual performance of the contract to protect our legitimate interests or those of third parties. Due to the multitude of processing contexts that are theoretically conceivable, the following points should only be understood as a selection of the most practice-relevant situations. We can provide more detailed information within the framework of specific claims for information. This includes in particular

        • the consultation of and data exchange with credit agencies (e.g. SCHUFA) to determine creditworthiness and default risks in our transactions
        • the review and optimization of procedures for demand analyses for the purpose of direct customer approach,
        • advertising or market and opinion research, unless you have objected to the use of your data,
        • the recording and storage of contact data when business cards are handed over in the event of someone being interested in our services, e.g. at trade fairs,
        • the enforcement of legal claims and defense in legal disputes,
        • ensuring the company’s IT security and operation,
        • the prevention and investigation of criminal offences,
        • video surveillance for the protection of domiciliary rights, for the collection of evidence in the event of burglary (see also Section 4 BDSG),
        • measures ensuring building and plant security (e.g. access controls),
        • measures to secure domiciliary rights,
        • measures for business management and further development of services and products, - risk management in the Webasto Group.

        based on your consent (Article 6(1) lit. a GDPR)

        If you have granted your consent to the processing of personal data for specific purposes (e.g. advertising measures for non-customers or the use of photographs), the lawfulness of this processing is established by virtue of this consent.

        A given consent can be revoked at any time. This also applies to the revocation of declarations of consent issued to us prior to the validity of the GDPR, i.e. before 25 May 2018. The withdrawal of a consent only takes effect for the future and does not affect the lawfulness of the data processed until this withdrawal.

        (2) Based on legal requirements (Article 6(1) lit. c GDPR)

        In addition, as a company, we are subject to various legal obligations, i.e. statutory requirements (e.g. German Money Laundering Act [Geldwäschegesetz, GwG], tax laws and regulatory requirements). The purposes of processing include, among other things, creditworthiness checks, identity and age checks, fraud and money laundering prevention, compliance with control and reporting obligations under tax law, and the assessment and management of risks within the company.

      4. Transfer of personal data to third parties

        We transfer your data to other companies in the Webasto Group for general administrative purposes in accordance with Article 6(1) lit. f GDPR and to our authorized dealers and service partners if required in order to respond to your enquiry or to fulfil the contract. If you request an offer from a dealer via our website www.webasto-comfort.com, we will pass on the personal data you have provided to the dealers you have selected.

        Webasto will of course be happy to support you in the context of a justified request to access or erase data by also forwarding the request to the service provider on your behalf.

        With regard to the transfer of data to recipients outside of our company, it should first be noted that we only transfer required personal data in compliance with the applicable data protection regulations. We are only allowed to transfer personal data of our suppliers if this is required by law, if the person concerned has consented to such or if we are otherwise authorized to do so. Under these conditions, recipients of personal data may be, for example:

        • public authorities and institutions (e.g. tax authorities, criminal prosecution authorities) where there is a legal or official obligation,
        • creditors or insolvency administrators enquiring within the scope of execution writs
        • public auditors. Data cannot be transferred to any other third parties unless you have expressly consented to this.
      5. Duration of the storage

        We process and store your personal data as long as this is necessary for the fulfilment of our contractual and legal obligations.

        If the data is no longer required for the fulfilment of our contractual or legal obligations, it is deleted at regular intervals, unless its – time-limited - further processing is necessary for the following purposes:

        • compliance with obligations to preserve business records under commercial and tax law,
        • German Commercial Code [Handelsgesetzbuch, HGB], Fiscal Code of Germany [Abgabenordnung, AO], or the German Money Laundering Act [Geldwäschegesetz, GwG]. The periods for storage and documentation specified there are generally two to ten years.
        • Preservation of evidence within the framework of the statutory statute of limitations. According to Sections 195 et seq. of the German Civil Code [Bürgerliches Gesetzbuch, BGB], these limitation periods can be up to 30 years, whereby the regular limitation period is 3 years.
      6. Your rights:

        You have the following legal rights regarding the processing of your personal data:

        • the right of access to your stored personal data;
        • the right to rectification;
        • the right to erasure;
        • the right to object;
        • the right to restriction of processing;
        • the right to data portability.

        You can withdraw your approval of the processing of your personal data at any time.

        In addition, you have the right to appeal to the competent data protection supervisory authority in Bavaria (Article 77 GDPR in conjunction with Section 19 BDSG).

        Should you no longer agree to the storage of your personal data or should this data have become inaccurate, we will, upon receipt of corresponding instructions, arrange for the deletion, amendment, or blocking of your data within the limits of the relevant statutory provisions. Upon request, you will receive information regarding all of your personal data that we have stored on you free of charge. The restrictions according to Sections 34 and 35 BDSG apply to the right of access and the right of erasure. If you have any questions regarding the collection, processing, or use of your personal data, for information, rectification, blocking, or erasure of data as well as for the use of further rights, please contact the Webasto Group Data Protection Officer (dataprotection@webasto.com) or the respective Webasto Group company in writing.

      7. Use of cookies

        Cookies are used on our websites. Cookies are small text files that are placed on your computer when you visit our websites. We set cookies for the purposes of guaranteeing the use of our online services, for individual website optimization and to guarantee IT security. For further information on our cookies, please click here.

        When you visit our website, we display a so-called "cookie banner" in which you can give your consent to the use of cookies on this website by pressing a button. Your selection will also be saved for future visits on our website.

        Cookies that are absolutely necessary to use our online services or to guarantee IT security do not require your consent. The use of these cookies and related processing activities are permitted by Article 6(1) lit. f) GDPR.

        Cookies for all other purposes, such as for individual website optimization, for marketing or for carrying out statistical evaluations of your activities on our website, however, require your consent.

        If you no longer wish us to use cookies at a later date, you have the option of changing the selection made for the use of cookies. To do so, you can adjust the settings for cookie management in your Internet browser. Here, in particular, the deletion of cookies that have already been placed can be initiated or the setting of cookies can be blocked for the future. Please note that the settings may vary depending on the browser you are using.

      8. Links to other websites

        Our online presence includes links to other websites. We do not have any influence over whether the operators of these websites comply with the relevant data protection regulations. So you should examine the data protection policies offered separately in each case. Nor do we have any influence whatsoever over the lawfulness of the contents of these websites. We therefore reject any responsibility for the contents of other websites.

      9. Matomo

        These technologies are used by advertisers to serve ads that are relevant to your interests.

        Processing Company: Matomo org. , 150 Willis St, 6011 Wellington, New Zealand

        Data Purposes:

        • Analyst
        • Event tracking

        Technologies Used:

        • Accept Cookies

        Data Collected:

        This list represents all (personal) data that is collected by or through the use of this service.

        • Time of previous visit of users
        • Screen Resolution
        • Files clicked or downloaded
        • Left to outside the domain clicked
        • User id
        • IP-Address
        • Page Speed
        • Page URL
        • Number of visits of users
        • User Agent
        • Browser-Information
        • Time zone
        • Time of first visit of users
        • Date and time of the visit
        • Page title
        • referrer URL
        • User data
        • Device Information
        • Geographic Location

        Legal Basis

        • Art. 6 para. 1 sentence 1 letter a GDPR

        Location of Processing: European Union

        Retention Period:

        The data will be deleted as soon as they are no longer needed for the processing purposes.

        Data Protection Officer of Processing Company:

        Below you can find the email address of the data protection officer of the processing company.
        privacy@matomo.org

        Further Information and Opt-Out

        Click here to opt out from this processor across all domains https://matomo.org/privacy-policy/#optout
        Click here to read the privacy policy of the data processor https://matomo.org/privacy-policy/
      10. Facebook Pixel

        This is a tracking technology offered by Facebook and used by other Facebook services such as Facebook Custom Audiences

        Processing company: Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin, D02, Irland

        Data Purposes:

        • Advertising
        • Marketing
        • Retargeting
        • Tracking
        • Analyse

        Technologies Used:

        • Accept Cookies

        Data Attributes:

        • Pixel Specific Data
        • Http-Header
        • Optional Parameters

        Data Collected:
        This list represents all (personal) data that is collected by or through the use of this service.

        • Facebook User ID
        • Browser Information
        • Usage Data
        • Device Information
        • Non-sensitive Custom Data
        • Referrer URL
        • Pixel ID
        • Location Information
        • Pixel Specific Data
        • User Behaviour
        • Ads Viewed
        • Interactions with Advertidement, Services and Products
        • Marketing Information
        • Content viewed
        • IP Address

        Legal Basis:

        • Art. 6 para. 1 sentence 1 lit. a GDPR

        Location of Processing: European Union

        Retention Period:
        The data will be deleted as soon as they are no longer needed for the processing purposes.

        Data Recipients: Facebook Inc.

        Data Protection Officer of Processing Company:

        Below you can find the email address of the data protection officer of the processing company.

        https://www.facebook.com/help/contact/540977946302970

        Further Information and Opt-Out:

        Click here to opt out from this processor across all domains https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

        Click here to read the privacy policy of the data processor https://www.facebook.com/privacy/explanation

      11. YouTube

        This is a video player service.

        Processing Company: Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

        Data Purposes:

        • Displaying Video

        Data Attributes:

        • Referral URL
        • Information if you have visited the website before
        • Identify if you are signed in to your Google Account

        Data Collected:

        This list represents all (personal) data that is collected by or through the use of this service.

        • IP Address

        Legal Basis:

        • Art. 6 para. 1 sentence 1 letter a GDPR

        Location of Processing: European Union

        Retention Period:
        Data will be deleted as soon as they are no longer needed for the processing purposes.

        Data Recipients: Alphabet Inc.

        Further Information and Opt-Out:

        Click here to opt out from this processor across all domains https://safety.google/privacy/privacy-controls/

        Click here to read the privacy policy of the data processor https://policies.google.com/privacy?hl=en

      12. Newsletter

        We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as "newsletter") only with the consent of the recipient or as permitted under law. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user.

        If you subscribe to our newsletter, we will use the data required for this purpose or separately provided by you in order to send you our e-mail newsletter on a regular basis. Unsubscribing from the newsletter is possible at any time and can be done either by sending a corresponding request to the contact person indicated below or via a link provided for this purpose directly in the newsletter.

        In order to subscribe to the newsletter, it is sufficient to enter your e-mail address. The registration to our newsletter is carried out in a so-called double-opt-in procedure. This means that, after subscribing, you will receive an e-mail in which you will be asked to confirm your subscription. This confirmation is necessary in order to ensure that nobody can subscribe using the e-mail address of someone else.

        Subscriptions to the newsletter are recorded in order to ensure that we can verify the registration process according to the statutory requirements. This includes the storage of information on the time of the registration and confirmation as well as the IP address.

        You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent. At the same time, your consent to its dispatch will expire. You can find a link for the cancellation of the newsletter at the end of each newsletter.

      13. Questions and comments

        If you have any questions, suggestions or comments on the subject of data protection, please send an e-mail to our Group Data Protection Officer (dataprotection@webasto.com). As a result of the rapid development of new Internet technologies, periodic updates and adjustments to our data protection declaration / privacy policy are required. You will be informed about any changes here. Controller within the meaning of data protection law

        Responsible authority within the meaning of data protection laws:

        Webasto SE
        Kraillinger Straße 5
        82131 Stockdorf
        Germany 

        You can contact our Group Data Protection Officer at:
        Mr. Reinhard Bersch
        dataprotection@webasto.com
        Phone: +49 (89) 8 57 94-0

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