We are pleased about
your interest in the Schaeffler Group (Schaeffler
AG and affiliated companies) and our products. The protection of your privacy when using our online
offer is very important for us. If personal data is processed, we follow the
applicable data protection laws.
1.
General information about data
processing
1.1.
Scope and purpose of processing of
personal data
In principle, we collect and use your
personal data only insofar as it is necessary to provide
a functional website, as well as our content and services
offered on the website. The processing of your personal data takes place either on the basis
of your consent or to the extent as the legal regulations allow this data
processing even without consent.
1.2.
Legal basis for data processing
Your personal data is
processed on the basis of the EU General Data Protection Regulation
(GDPR) and the applicable local data protection law.
1.2.1.
Given consent to the processing Art.
6 (1) lit. a GDPR
Insofar as you have given us consent
to process personal data for specific purposes, Art. 6 (1) lit.
a GDPR serves as the legal basis for the processing of personal data. Consent
given can be revoked by you at any time. Please
note that the revocation is only effective for the future. Processing that took place before the revocation is not affected.
1.2.2.
Pre-contractual and contractual
measures Art. 6
(1) lit. b GDPR
Processing of personal data in the
context of the performance of a contract to which you are a party or in order
to take steps prior to entering a contract at your request is based on Art. 6
(1) lit. b GDPR.
The purposes of data processing are governed by the
respective contract documents and the subject matter of the contract.
1.2.3.
Legal obligation Art. 6 (1) lit. c
GDPR
If processing of personal data is
necessary to comply with a legal obligation to which we are subject, Art. 6 (1)
lit. c GDPR serves as a legal basis.
1.2.4.
Legitimate interests Art. 6 (1) lit.
f GDPR
If processing is necessary for the purposes of the
legitimate interests pursued by Schaeffler or by a third party (e.g.,
to assert legal claims and defend against legal disputes; to ensure IT
security; to prevent criminal acts; for business management measures and for the further development of
services and products) and if your interests, fundamental rights and freedoms
as data subject do not override the aforementioned interest, Art. 6 (1) lit. f
GDPR serves as the legal basis for processing.
1.3.
Data erasure and retention period
We process and store your personal data for as
long as this is necessary to satisfy the respective purpose. If your data is no
longer required to fulfil the purpose of the data processing, it will be
deleted, unless this deletion is subject to statutory retention obligations. The
data that you have given us, when submitting a marketing consent will be
deleted after two months at the latest upon request, otherwise we will delete
the history of our marketing communication with you after five years at the
latest.
1.4.
Access to personal data within the
Schaeffler Group and by third parties
Within the Schaeffler Group, those entities
gain access to your data who require it as a part of “least privilege”
(assignment of user rights to the lowest possible extent) and the
“need-to-know” principle (knowledge of data only if necessary).
We may only transfer data to third parties
outside the Schaeffler Group if this is necessary, if statutory provision so
requires, if you have given your consent or processors commissioned by us have
contractually agreed to comply with the requirements of the GDPR and applicable
local data protection law.
Under these circumstances, recipients of
personal data may include: Responsible internal departments, which are
responsible for the processing of your data, and service providers if required.
1.5.
Transfer of personal data to a third
country or to an international organisation
A transfer of data to countries outside the
EU/EEA (so-called third countries) will only take place as it is necessary or
required by law, you have given your consent or as part of data processing by a
processor. If service providers in third countries are deployed, in addition to
written instructions, they are required to comply with data protection
standards in Europe by agreeing on the EU standard contractual clauses.
1.6.
IT security and links to third party
websites
The Schaeffler Group uses technical and organizational security
measures to protect your data that we manage against accidental or
intentional destruction, manipulation, loss or access by unauthorized persons. These safeguards are constantly being developed in
accordance with the respective new technical possibilities
Our websites may contain links to the websites of other providers.
Our Privacy Policy does not apply to these websites.
1.7.
Obligation to provide personal data
While entering
into a contract, you must provide the personal data that is necessary to establish,
implement and terminate the contract and to satisfy
the resulting duties or that Schaeffler
must collect due to legal provisions.
If we provide you with offers and services on this
website that you can voluntarily use, there is no duty to
provide your data to us, but without your personal data, you
may not be able to use or benefit of our offers and
services.
1.8.
„Profiling“ and automated
decision-making
We do not use
fully automated decision-making pursuant to Art. 22 GDPR.
Schaeffler basically does not use “profiling”. If we use it in
individual cases, we will inform you about this
separately, if it is required by law and – if necessary
- obtain your prior consent.
1.9.
Sources of your personal data
We use data that we receive from you through
personal contact, registration forms or social media channels.
2.
Data processing for the provision of
the website and the creation of log files
By default, when you visit our website, our web servers obtain
and collect the name of your Internet service provider, your IP
address, the website from which you are visiting us, the
websites you visit on our website, and the date and
duration of the visit. This data is stored in
the log files of our systems and is used for problem or error
analysis. However, the use of the IP address
is limited to the technically necessary extent and
is abbreviated and therefore used only anonymously, so that
it is not possible to assign the IP address to a user. The data is not
merged with personal data.
The temporary storage of the abbreviated IP address by our systems is
technically necessary to display the website to your terminal device. Storage in log files is done to
ensure the functionality of the website. Data is not being analyzed for marketing purposes in this
context.
For these purposes, we have legitimate interest in processing
of data according to Art. 6 (1) (f) GDPR.
The collection of data for
the provision of the website and the storage of data
in log files is essential for the operation of the
website. Therefore, there is no possibility for you
as a user to object to such processing.
3.
Data processing in respect of
services offered on the website
On our website various services are offered, for the
use of which we request personal data from you.
3.1.
Data processing in the context of
marketing activities (DOI, Tracking)
We want to provide you with information whichis
individually tailored to your interests as much as possible. In order for you
to use these services, we will require personal data from you, such as your
name, e-mail address, company, job title, if available, the customer number
and/or telephone number, which you can provide to us via a registration form on
one of our registration pages, as well as your combined consent.
-
In
the sending of personalized advertising and information (e.g newsletters,
invitations trade fairs and events, products, services, offers and promotions
including opinion surveys and company communications) of the Schaeffler Group
by e-mail, SMS and/or instant messenger services such as e.g WhatsApp and
-
In the tracking of your
user behavior in connection with digital Schaeffler offers (when did you
receive and read e-mails sent to you by us; which sections, articles, products,
and other content on Schaeffler websites and in e-mails did you access and
when; which links in our e-mails on Schaeffler websites did you use and when;
how did you interact with our services, e.g participation in a webinar.
The collection of your data via the
registration form serves to send advertisements and information to you. For
this purpose, we may also engage third parties (service providers) with whom a
contract for order processing is valid/signed and transfer your data to such
third parties. The tracking information of your usage behavior, serves
exclusively, to be able to send you information and advertisements tailored to
your interests as individually as possible.
If you give your consent and submit the
registration form, you will receive a confirmation e-mail from us to your provided
e-mail address. The registration will only become effective once you have
clicked on the confirmation link within the e-mail.
The legal basis for the processing of your
personal data after registration is Art. 6 (1) lit. a GDPR.
The data will be deleted as soon as they are no
longer required to achieve the purpose for which they were collected.
Therefore, the data is stored as long as the registration for the personalized
advertising and information service is active. At any time you have the
possibility to revoke your consent to the processing of personal data by e-mail
to unsubscribe@schaeffler.com or by clicking on the „unsubscribe link” in
the received messages, with effect for the future and thereby unsubscribe from
the service. In this case, all personal data stored in the course of contacting
us as well as information about your usage behavior will be deleted. The
revocation of consent does not affect the lawfulness of the processing carried
out on the basis of the consent until the revocation.
3.2.
Use of our contact and request forms
The website has contact
and request forms that can be used to contact us
electronically.
To use the contact forms, you must fill the mandatory information
in the respective input mask marked by an asterisk (e.g.
your e-mail address). All other information is optional for you. This personal data will be sent to a department
of our company that is responsible for processing and stored in our systems. At the time of sending your message, the date and time
of the entry will be saved. We will obtain your consent for processing of the data during the
inquiry process.
The data filled in the input mask will be used
exclusively to process your inquiry.
The legal basis for the processing of your personal data
is Art. 6 (1) (a) GDPR.
The data will
be erased as soon as the communication
process is completed.
You have the right withdraw your consent to the
processing of personal data at any time to by sending
an e-mail to dataprivacy@schaeffler.com. In this case, all personal data stored as part of the
contact will be deleted with effect for the
future. Depending on the time of your withdrawal, we may not be
able to answer your request.
The specific learning management system offered
on this platform means that e-learnings, web seminars, workshops, videos,
tutorials, instructions, checklists, physical training, and blended learning
training are offered in a target group-oriented manner. In the course of this,
it is necessary to use these offers by providing the personal data required for
the inquiry and booking. In addition to this, your registration will provide
you with a learning history including the certificates you have acquired
3.3.
Data processing when registering for
non-open websites/ website areas
Some of our websites or individual areas of our
websites are access-protected. This means that you have to register in advance
in order to visit and use the website or the website sections.
To carry out a registration, you have to enter
the data marked as mandatory in a corresponding input mask, for example your
contact & address data and your user type. The data and time of your entry
will be saved.
We use your data to manage your user account
and to contact you in terms of an order processing and services. In addition,
transaction data can be recorded on the website, which serves to display a
history of already visited pages within the portal as a convenience function.
The data will be stored by us until you delete your user account.
3.4.
Data processing for orders
You can order products, services and non-cash
rewards offered on our websites. To place an order, first you must enter your
contact and address data in a corresponding input mask (f.e. as part of a
registration for the website). The date and time of your
entry will be saved. Your personal data will be stored by us and passed on to our
third-party service providers, if necessary, for delivery.
The legal basis for the
processing of your personal data is Art. 6 (1) lit. b GDPR.
The personal data will be stored by us until
the order and shipping process has been completed and there are no longer any
statutory retention periods.
You have the possibility to revoke your consent
that you have provided to us in the context of an order at any time by sending an e-mail
to dataprivacy@schaeffler.com. In this case, all personal data will be deleted with effect for the
future, provided that the deletion does not conflict with any statutory
retention periods.
3.5.
Data processing in connection with
Cookies, Web Beacons and Local Storage
3.5.1.
Cookies
We use cookies to enable you to make the best possible use of
the website. Cookies are text
files that are stored in the Internet browser
or saved by the Internet browser on the terminal device of the
user. If a user visits our website, a
cookie can be stored on the user’s operating system. This cookie contains a characteristic string that allows clear
identification of the browser when the website is accessed
again. We also
use cross-domain cookies, which are used to transfer session information from
one or more other domains. This means that your user data can be used not only
on the generating domain but also on other Schaeffler websites. The requirement
for the use of cross-domain cookies is that they are used on websites within an
application and identical cookies on the websites and make our websites more
user-friendly.
In the following, we provide you with general
information about the use of cookies on our website and the
associated processing of personal data. For further information on specifically used cookies, please
refer to the Schaeffler Cookie Policy published on this website.
We use cookies to make our website more user-friendly. Some elements of our website require
the requesting browser to be identified even after a
page break.
In addition, we use cookies on our website to
allow the analysis of the user’s surfing behavior.
When visiting our website the user is informed about the
use of cookies and referred to this privacy policy.
Some features of our website cannot be offered without the use
of cookies. It is necessary that the browser is recognized even after
a page break.
The user data collected
through the technically necessary
cookies will not be used to create user profiles. Further information can be found in the Schaeffler
Cookie Policy.
Analysis
cookies are used to improve the quality of our website and its content. Analysis cookies show us how the
website is used, so that we can constantly optimize our offer.
Further information can be found in the Schaeffler
Cookie Policy.
Cookies are stored on the user's terminal
device and transmitted from it to our website. Therefore, you as a user also
have full control over the use of cookies. By changing the settings in your
internet browser, you can disable or restrict the transmission of cookies.
Cookies that have already been stored can be deleted at any time. This can also
be done automatically. If cookies are deactivated for our website, it may no
longer be possible to use all functions of the website in full.
The legal basis for the use of necessary
cookies is Art. 6 (1) p. 1 lit. b GDPR. For the use of cookies for analysis or
marketing purposes, the legal basis is Art. 6(1) lit. a GDPR or Art. 6 (1) p. 1
lit. f GDPR. Cookies serve statistical purposes and purposes of personalization
in the further development and relevance of the website and represent a
legitimate interest of Schaeffler.
3.5.2.
Web-Beacons
Web beacons
are small graphic files (also referred to as "counting pixels",
"pixel tags" or "clear GIFs") that may be included in our
websites, apps, applications and newsletters and are usually used in
conjunction with cookies. The above statements on cookies apply accordingly to
web beacons; web beacons are not used in particular if you have objected to the
use of the relevant cookie.
The legal basis for the use of web beacons is
Art. 6 (1) p. 1 lit. f GDPR. Web beacons serve statistical purposes and
purposes of personalization in the further development and relevance of the
website and represent a legitimate interest of Schaeffler.
3.5.3.
Local Storage
We use the functionality of the so-called
local storage. Your data (master data, status data and program data) are stored
locally in the cache of your browser. If you don’t delete the cache of your
browser, this information is retained and can be read out the next time you
visit the website. By using a local storage, we enable you to view your data
correctly while browsing on our website without slowing down this process
unnecessarily and overloading the interfaces.
If you do not wish to use the local storage, you can set this
accordingly in the settings of your respective browser at any time. Please note
that, in this case, the functionalities of our website will only be available
to you to a limited extent or are no longer available.
The legal
basis for the use of local storage is Art. 6 (1) p. 1 lit. f GDPR. Schaeffler's
legitimate interest in using local storage is to accelerate processes and avoid
system overload.
3.6.
Data processing in connection with
social media networks
The following information of the privacy policy
applies to the Schaeffler Group's appearances on social media or third-party
platforms:
-
Twitter
-
LinkedIn
-
Instagram
-
YouTube
-
XING
-
WeChat
-
VKontakte
-
Facebook
The
declaration below on the processing of personal data refers purely to the
processing by the Schaeffler Group itself. The providers of the listed social
media process personal data of registered users, but also of non-registered
visitors to their websites by applying their own policies. They are responsible
for their own user data processing policies. The user or visitor should inform
about the data processing by the social media sites directly from the social
media providers.
The
respective legal entity within the Schaeffler Group's legal entities is
responsible for the collection of data for the above-mentioned social media
presence.
We collect
and process personal data in the course of the use of our social media sites by
the data subjects and may transfer your data to an internal system for
processing regarding this purpose.
3.6.1.
Processing of your personal data when
contacting us
If you
provide us with personal data by contacting us, e.g. by e-mail or by a direct
message within social media, we process your data pursuant to Art. 6 (1) p. 1
lit. b GDPR for the purpose of fulfilling the contract or for the implementation
of pre-contractual measures that are carried out in response to your request or
pursuant to Art. 6 (1) p. 1 lit. f GDPR due to our legitimate interest in
answering your request. Thereby, we process the data that you provide to us
directly via your inquiry. In social media, this is your username and your
photo as well as the message you send us. It may also happen that we visit your
public profile and store data from it, provided that this is necessary for the
above-mentioned purposes.
The
processing of the named personal data is carried out according to Art. 6 (1) p.
1 lit. f GDPR on the basis of Schaeffler's legitimate interest in providing
users with targeted information about us and our services, as well as the optimized design of our social media presences and
effective communication with users. If users are asked by the respective
providers of the social media networks for consent to this data processing
(e.g. when registering by checking a checkbox or confirming a corresponding button),
the legal basis for the processing is Art. 6 (1) p. 1 lit. a GDPR.
3.6.2.
Processing of Schaeffler's personal
data within social media networks
For all our
social media presences, we receive messages about whether users of the social
media give a "like" for our posts, finds them interesting, share or
recommend or comment (depending on the function of the social media), etc. we
may also see a list of our respective followers or subscribers, and on some social
media sites (for example XING) a list of visitors to our social media presence.
In addition, we can see when you leave reviews about our company, provided that
this review is linked to the respective social media presence.
The
processing of the named data is carried out according to Art. 6 (1) p. 1 lit. f
GDPR on the basis of Schaeffler's legitimate interest in providing users with
targeted information about us and our services, as well as the optimized design
of our social media presences and effective communication with users. If users
are asked by the respective providers of the social media networks for consent
to this data processing (e.g. when registering by checking a checkbox or
confirming with a corresponding button), the legal basis for the processing is
Art. 6 (1) p. 1 lit. a GDPR.
3.6.3.
Processing of statistical data within
social media networks
We also
receive statistical evaluations of the use of our social media sites from all
social media providers. Beyond the information mentioned under 3.5.1, however,
this only contains anonymized information, such as (depending on the provider)
demographic data, an anonymized analysis of the interaction and reach of our
social media presences and posts, anonymized information such as languages,
interests and end devices used by our users.
The
processing of the named data is carried out according to Art. 6 (1) p. 1 lit. f
GDPR based on Schaeffler's legitimate interest in providing users with targeted
information about us and our services, as well as the optimized design of our
social media presences and effective communication with users. If users are
asked by the respective providers of the social media networks for consent to
this data processing (e.g. when registering by checking a checkbox or
confirming a corresponding button), the legal basis for the processing is Art.
6 (1) p. 1 lit. a GDPR.
3.6.4.
Processing of data for advertising
purposes and creation of usage profiles by the providers of the social media
networks
The data
mentioned under 3.5.1 and 3.5.2 may also be processed for market research and
advertising purposes. This happens, for example, when we place advertisements
on the respective social media. However, the data is processed by the
respective providers. Please also note that they can create usage profiles from
your usage behavior. These usage profiles can in turn be used, for example, to
place advertisements within and outside the platforms that correspond to your
developed interest profile. Please inform yourself about this with the
providers of the social media.
The social
media providers do not act according to instructions but process your data on
their own responsibility. You can find information about the providers and
their contact details on their websites. There you will also find information
about the processing of your personal data. We would like to point out that
your data may be processed outside of the European Union by the providers of the
social media. This may result in a risk for you, for example, it could be more
difficult to you to enforce your rights. Please inform yourself in this regard
with the providers of the social media.
4.
Your rights as data subject
If your personal data is
being processed, you are the data subject pursuant to the GDPR and you have the
following rights:
4.1.
Right of access (Art. 15 GDPR)
Upon
request you can obtain confirmation from us as to whether your personal data is
being processed by us. If this is the case, you can request us to give you
access to the information provided for by law (see Art. 15 (1) GDPR). We will
also notify you of appropriate safeguards pursuant to Art. 46 GDPR in the
context of data transfer in case your personal data is being transferred to a
third country or to an international organization. There are the restrictions
according to Art. 34 and 35.
4.2.
Right to rectification (Art. 16
GDPR)
You have a right to rectification and/or
completion if the processed personal data is inaccurate or incomplete. We have
to rectify the data without due delay.
4.3.
Right to restriction of processing
(Art. 18 GDPR)
Provided that the legal requirements are met
(see Art. 18 (1) GDPR), you have the right to restrict processing of your
personal data. For consequences of the restrictions please refer to Art. 18 (2)
and (3) GDPR.
4.4.
Right to erasure (Art. 17 GDPR)
You have the right to demand from us erasure of
your personal data without undue delay, and we are obliged to immediately erase
this data if any of the reasons pursuant to Art. 17 (1) GDPR applies. The right
to erasure does not apply in cases of Art. 17 (3) GDPR. Furthermore, there are
restrictions according to Art. 34 and 35 BDSG.
4.5.
Right to notification
If you have exercised your right to
rectification, erasure, or restriction of processing, we are obliged to notify
each recipient to whom the personal data have been disclosed of this
rectification, erasure, or restriction of processing, unless this proves impossible
or involves disproportionate effort. We have to inform you about those
recipients upon your request.
4.6.
Right to data portability (Art. 20
GDPR)
You have
the right to receive your personal data that you have provided to us in a
structured, commonly used and machine-readable format. For details, please
refer to Art. 20 GDPR.
4.7.
Right to object (Art. 21 GDPR)
You have the right to object at any time to the
processing of your personal data that is based on Art. 6 (1) (e) or (f) GDPR on
grounds relating to your particular situation. Further details can be found in
Art. 21 GDPR.
In
addition, you have a right to lodge a complaint with a supervisory authority
pursuant to Art. 77 GDPR.
5.
Name and contact details of the
controller
Schaeffler Technologies AG & Co. KG
Industriestraße 1-3
91074 Herzogenaurach
Germany
Phone number: +49 9132 82-0
Fax: +49 9132 82-49 50
E-Mail: info.de@schaeffler.com
6.
Contact details of the data
protection officer
Schaeffler
Technologies AG & Co. KG
Data
protection officer
Industriestraße 1-3
91074 Herzogenaurach
Germany
Phone number: +49 9132 82-1476
Fax: +49 9132 82-5901
E-Mail: dataprivacy@schaeffler.com
Status: Version 2.0, 10.2021