Data Protection Notice

Data protection information for the processing of personal data on the website https://mahle-smartbike.com/

1. The controller for the purposes of the EU General Data Protection Regulation (GDPR) is:

MAHLE Smartbike Systems SLU
Orfebres 10, Palencia
34004
Spain
mahle.support@heloo.com

2. Data protection officer:

MAHLE GmbH
Corporate Data Protection Officer
Dr. Alexander Deicke
70376 Stuttgart
Germany
e-mail: cdpo@mahle.com

3. Legal specifications

MAHLE is committed to strict compliance with the national and international laws and regulations to safeguard the right to informational self-determination.
We observe European regulations on data protection and privacy law and the national provisions that arise from them in collecting, storing, and processing personal data.

4. Collection and processing of your personal data

When you visit our websites, we automatically store on an anonymized basis the name of your In-ternet service provider, the website from which you visit us, the Web pages you visit when you are on our site, websites you visit from our site, and the date and duration of your visit. We may analyze and interpret this information on an anonymized basis. Further personal data are not collected or stored unless you expressly permit us to do so. Our data protection information applies exclusively to the use of our websites, not to your activities on the websites of social networks or other provid-ers that you may be able to reach using the links on our websites. Please consult these providers’ websites for information on their privacy and data protection policies.
Where permissible by law, we disclaim any and all liability for damage and/or losses arising from the use of the linked websites.
We do not store other personal data unless you communicate these data to us, for example within the scope of a contact form, a survey, a prize competition, registration, or to perform a contract, and even in these cases we do so only to the extent that we are permitted to do so based on your con-sent or pursuant to the applicable legal provisions (see “Legal basis for processing”).
There is no legal or contractual obligation for you to provide your personal data. However, it is pos-sible that certain functions of our website may depend on the provision of personal data. If you do not provide personal data in these cases, this may cause certain functions to be restricted or una-vailable.

5. Purposes of processing of personal data

Your personal data are used only for the purpose for which you have voluntarily provided these data to us and to protect our IT systems against attacks and other unlawful actions. Should you have communicated further personal data to us, for example within the scope of a contact form, a survey, a prize competition, registration, or to perform a contract, we process these data for the purposes mentioned, for purposes of customer management and – to the extent necessary – for purposes of executing and billing for any business transactions, in each case in the scope necessary to that end. We obligate our employees and service providers to observe the strictest confidentiality.

6. Legal basis for processing

Where you have consented to our processing of your personal data, this consent constitutes the legal basis for the processing (point (a) of Article 6(1) GDPR).
Point (b) of Article 6(1) GDPR forms the legal basis for processing of personal data for the purpose of taking steps prior to entering into a contract or performing a contract with you.
Where the processing of your personal data is necessary to fulfill our legal obligations (e.g., to store data), we are authorized to do so pursuant to point (c) of Article 6(1) GDPR.
Beyond that, we process personal data for the purposes of the legitimate interests pursued by us or by a third party in accordance with point (f) of Article 6(1) GDPR. Maintaining the functionality of our IT systems, marketing our own and third-party products and services, and the legally required doc-umentation of business contacts constitute such legitimate interests.

7. Disclosure of personal data to third parties

Except in the cases indicated separately, we share your personal data with third parties only if

• you have consented pursuant to point (a) of Article 6(1) GDPR,
• this is necessary for the performance of a contract with you pursuant to point (b) of Article 6(1) GDPR, or
• in the event that there is a statutory obligation of disclosure pursuant to point (c) of Article 6(1) GDPR.
• this takes place for the purposes of the legitimate interests pursued by the controller pursu-ant to point (f) of Article 6(1) GDPR. Examples include:
  – Reviewing and optimizing procedures for analyzing demand for purposes of directly ap-proaching customers
  – Optimization and demand-driven design of the website
  – Advertising or market and opinion research, to the extent that you have not objected to the use of your data
  – Safeguarding our company’s IT security and IT operations
  – Preventing and investigating criminal acts
  – Measures for managing the business and further developing services and products

If personal data are transferred to a third country outside the European Economic Area (EEA) or to an international organization, this is stated separately.

8. Processing of personal data for the purpose of sending newsletters

We are happy to keep you informed of current news on the basis of your consent (point (a) of Article 6(1) GDPR) via the specific newsletter offered on the website.
For us to send out a newsletter, you need to provide us with the required information indicated (e.g., name and e-mail address). You can also enter and submit further information voluntarily. After you have communicated your e-mail address to us, you will receive an e-mail from us at the e-mail ad-dress you provided, asking you to click a confirmation link to verify the e-mail address you provided (known as a “double opt-in” process).
We will store your data only for purposes of sending out our newsletter. We will also store your IP address and the date when you registered so we have documentation that you signed up for the newsletter in case of any doubt. To measure our newsletters’ success, we also collect information on whether newsletters are opened, when they are opened, and which links are clicked.
You can unsubscribe from the newsletter at any time by clicking the unsubscribe link in the newslet-ter footer.

9. Use of the contact form

When you contact us (e.g., via contact forms), we store your data for purposes of processing your inquiry (point (b) of Article 6(1) GDPR) and in the event that further correspondence should take place. Otherwise, your data are erased after your matter is processed. This does not apply to data for which there are statutory or otherwise stipulated obligations of storage.

10. Job applications

When you apply to work with us, we process the information that we receive from you as part of the application process, e.g., through application letters, CV, employment references. The information with special relevance to us includes not only your contact details, but also information about your education and training, qualifications, work experience, and skills.

Your personal data are initially processed exclusively to carry out the application process.

The legal bases for the data processing within the application process and as part of the personnel file are Sec. 26 (1) BDSG and Sec. 26 (2) BDSG, to the extent that you have given consent, for example by transmitting information not necessary to the application process. The legal basis for the data processing after an application has been rejected is point (f) of Article 6(1) GDPR. The legitimate interest in the case of processing on the basis of point (f) of Article 6(1) GDPR is our interest in defending against legal claims.

If your application is accepted, it goes into your personnel file and is used to carry out and terminate the employment relationship and then deleted according to the rules that apply to personnel files. If we are not currently able to offer you a position, we will continue to process your data for up to six months after the rejection notice is sent so that we can defend ourselves against possible legal claims, particularly relating to alleged discrimination in the application process.

We do not typically require any special categories of personal data within the meaning of Article 9 GDPR for the application process. We request that you not send us any information of this nature from the outset.

You are not obligated to provide us with personal data. However, we can only assess whether you are suitable for the specific position that enters into consideration if we receive information, particu-larly on your education and training, work experience, and skills, and we cannot include you in the application process if you do not provide your contact details.

11. Use of cookies

Cookies are small files that are placed on your desktop, notebook, or mobile device by a website that you visit. We can use cookies to determine things like whether there has been a connection between your device and our website in the past or what language or other settings you prefer. Cookies can also process personal data.
We use cookies (“strictly necessary cookies” and “analytical cookies”) to recognize your use inter-ests and particularly popular areas of our website and use this information to improve the design of the website and make it even more user-friendly.

a) “Strictly necessary cookies”
“Strictly necessary cookies” are essential to the basic functions of the website. These cookies can-not be deactivated. If you have disabled cookies in your browser, you may find that some functions are not available to you and/or the website does not display correctly. These cookies are:

b) “Analytical cookies”

We use “analytical cookies” to recognize your use interests and particularly popular areas of our website and use this information to improve the design of the website and make it even more user-friendly. You can click to consent to the use of analytical cookies:

You can click to withdraw your consent to the use of analytical cookies at any time:

These cookies are:

12. Use of Google Analytics

We use the “Google Analytics” Web analytics service on our website. The service provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses the analysis cookies noted above. The Google Analytics cookies are stored on the basis of point (a) of Article 6(1) GDPR. The data collected are anonymous to us as the opera-tor of this website. We cannot draw any conclusions regarding users’ identity.
We have activated the IP anonymization function on this website. This means that Google truncates (shortens) your IP address within Member States of the European Union or in other states that are signatories to the Agreement on the European Economic Area before transferring it to the United States. Only in exceptional cases is the full IP address transferred to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this infor-mation to analyze your use of the website, compile reports on website activity, and provide the web-site operator with further services associated with the use of the website and of the Internet.
We have entered into a contract for processing of data with Google.
You can object to the processing of data by Google at any time by using the opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de or via the ad display settings: https://adssettings.google.com/authenticated .

13. Use of YouTube

Our website uses embedded videos of the service “YouTube.” The service provider is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube is a platform that enables playback of audio and video files.
When you access a page of our website, the YouTube player embedded there establishes a connec-tion to YouTube to ensure the technical transfer of the video or audio file. Data are transferred to YouTube when the connection to YouTube is established.
The use of YouTube takes place in the interest of an appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of point (f) of Article 6(1) GDPR.
For information on the purpose and scope of the collection of data, the further processing and use of the data by YouTube, and your rights in this regard and possible settings to protect your privacy, please see the YouTube privacy policy. You can find it at:
https://policies.google.com/privacy?hl=de#intro

14. Use of Google Maps

We use maps from the “Google Maps” service on our website. The service provider is Google Ire-land Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to process your IP address.
The use of Google Maps takes place in the interest of an appealing presentation of our online offer-ings and ensuring that the places indicated by us on the website are easy to find. This constitutes a legitimate interest within the meaning of point (f) of Article 6(1) GDPR.
For more information on how user data are handled, please see the Google privacy policy. You can find it at:
https://policies.google.com/privacy?hl=de#intro

15. Visiting our online presence on social media

We maintain an online presence within social networks and on platforms in order to be able to com-municate with the customers, potential customers, and users who are active there and inform them there about our services.
Please note that user data may be processed outside the territory of the European Union during the course of these activities. This may give rise to risks for users because it could be more difficult for users to assert their rights, for example.
Furthermore, users’ data are typically processed for market research and advertising purposes. For example, user behavior and the interests of users indicated by that behavior can be used to create use profiles. These use profiles can in turn be used to serve ads that are presumed to match users’ interests on and off these platforms, for example. For these purposes, cookies are typically stored on users’ computers, storing their use behavior and interests. Furthermore, data can also be stored in the use profiles independently of the devices used by the users (especially if the users are mem-bers of the platforms in question and are logged in there).
For detailed information on the relevant types of processing and the possibilities of objecting (opting out), please see the information from the providers that is linked below.
In the case of inquiries concerning access to information and the assertion of user rights as well, please note that it is most effective to raise these matters with the providers. Only the specific pro-vider has access to users’ data and can take appropriate action directly and provide access to in-formation. Should you still need help even after contacting the providers, please feel free to contact us.

• Facebook, Facebook pages, Facebook groups (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – privacy policy, specifically for pages, opt-out:
  https://www.facebook.com/settings?tab=ads und http://www.youronlinechoices.com
• Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – privacy policy, opt out: https://policies.google.com/privacy?hl=de#intro
• Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – privacy poli-cy/opt-out: https://privacycenter.instagram.com/policy
• LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – privacy poli-cy, opt-out: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy
• Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – privacy policy, opt-out: https://privacy.xing.com/de/datenschutzerklaerung

16. Security

We take organizational and technical measures to ensure that those of your data that we process are protected against manipulation, loss, destruction, and access by unauthorized persons. We ad-just the security measures we take to this end to reflect the state of the art on an ongoing basis.

17. Erasure of your personal data

We erase your personal data as soon as the purpose for which we have collected and processed them ceases to apply. Storage takes place beyond that point in time only if this is necessary ac-cording to the laws, regulations, or other legal provisions of the European Union or a Member State of the European Union to which we are subject.

18. Rights of data subjects

Please note that as the data subject, you have the following rights in conjunction with the pro-cessing of your personal data:

• Right of access pursuant to Article 15 GDPR
• Right to rectification pursuant to Article 16 GDPR
• Right to erasure pursuant to Article 17 GDPR
• Right to restriction of processing pursuant to Article 18 GDPR
• Data portability pursuant to Article 20 GDPR

If you have consented to the processing of your personal data by us, you are free to withdraw your consent to the processing of your personal data at any time.
Finally, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you and to processing which is based on point (f) of Article 6(1) GDPR (data processing on the basis of weighing of interests). If you object, we will no longer process your personal data unless we demonstrate compelling legit-imate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
The lawfulness of processing of your personal data up until the withdrawal of consent is not affected by the withdrawal thereof. Withdrawal of consent also does not affect the possible further pro-cessing of these data on a different legal basis, for example to meet legal obligations (see the sec-tion titled “Legal basis for processing.”
If you consider that the processing of your personal data violates legal provisions, you have the right to lodge a complaint with a data protection supervisory authority with jurisdiction pursuant to Article 77 GDPR.

19. Contact person

If you have any questions regarding data protection at MAHLE or wish to exercise your right of ac-cess to information or to make declarations as a data subject, please contact our company’s Corpo-rate Data Privacy (CY) department. You can reach this department by e-mail at corpo-rate.data.privacy@mahle.com or use the official address of MAHLE International GmbH, Prag-straße 26-46, 70376 Stuttgart, Germany.

You can also reach our corporate data protection officer at the above address or cdpo@mahle.com.