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The controller for the purposes of the EU General Data Protection Regulation (GDPR) is:
MAHLE Smartbike Systems SLU
Orfebres 10, Palencia
34004
Spain
cdpo@mahle.com
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Data protection officer:
MAHLE GmbH
Corporate Data Protection Officer
Dr. Alexander Deicke
70376 Stuttgart
Germany
e-mail:
cdpo@mahle.com
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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.
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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.
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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.
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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.
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Disclosure of personal data to third parties
To fulfill the purposes described below, you are informed that Mahle Smartbike shares personal data with other entities in the group.
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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.
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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.
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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.
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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.
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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.
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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.
