WABCO Holdings Inc., together with its affiliates, (all together "WABCO", "We" or "Us") respects individual privacy and is committed to protect and maintain the privacy of personal information collected through the WABCO websites.
1. Personal information collected
We collect and process the following information about you:
Personal information that you provide us
1.1 We collect personal information that you voluntarily provide by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The information you give us may include:
- your name;
- email address;
- phone number;
Personal information that we automatically collect about you
1.2 We collect information automatically about your visits of WABCO websites. In particular, when you visit the WABCO websites, your browser automatically sends us certain Internet-related information, including:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
- your device ID
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products/services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number
2. Use of personal information
We process personal information collected via the WABCO websites for the purposes of:
Personal information that you provide us
2.1 We will use this information for:
- Dealing with your enquiries and requests;
- Providing you with information about WABCO products and services we feel may interest you.
Personal information that we automatically collect about you
2.2 We will use this information to:
- administer WABCO websites and run internal operations, including troubleshooting, data analysis and testing;
- identify problems with our servers;
- prepare aggregate demographic information and identify browser version and mobile device type regarding the use of the WABCO websites;
- keep WABCO websites safe and secure;
- improve the functions of WABCO websites and ensure that content is presented in the most effective way for you and your computer/device;
- better understand how visitors use WABCO websites.
4. Legal basis
4.1 Your information is being collected and processed on the following legal bases:
- If it is necessary for pursuing our legitimate interests, considering these interests are not overridden by your fundamental rights and freedoms, e.g. we use your information to administer, improve and secure the WABCO websites.
- If it is necessary for performing the contract we have with you, e.g. we collect your information in order to allow you to login on myWABCO; or
- When you consented to this, e.g. if you have given your prior express consent thereto we may use your email address for sending you our newsletter.
5. Personal information we share
5.1 For the purposes mentioned above, we may share your personal information with other entities within our group of companies, government bodies and law enforcement agencies (including police and judicial authorities), successors in title to our business and suppliers we engage to process data on our behalf (e.g. suppliers of IT related services, suppliers of HR related services and suppliers of marketing related services).
5.2 We will also disclose your personal information to third parties:
- in the event that WABCO sells or buys any business or assets, in which case WABCO may disclose your personal information to the prospective seller or buyer of such business or assets;
- if WABCO or substantially all of its assets are acquired by a third party, in which case the personal information WABCO holds about you may be one of the transferred assets;
- if WABCO is under a duty to disclose or share your personal information in order to comply with any legal obligation or to protect the rights, property, or safety of WABCO, its customers or others. This includes exchanging personal information with public authorities (including judicial and police authorities) in the event of, for example, a cyber security incident; and
- if you specifically consented thereto.
6. Transfer of your personal information
6.1 WABCO is a global business and has operations in many countries. Your personal information may be maintained at WABCO facilities worldwide.
6.2.1. In case your personal information is transferred outside of the EEA, WABCO will make sure that your personal information is protected by the following safeguards:
○ the laws of the country to which your personal information is transferred ensure an adequate level of data protection (Article 45 of the EU General Data Protection Regulation (2016/679)(GDPR));
○ the transfer is subject to data protection clauses approved by the European Commission (Article 46.2 GDPR) or is subject to the EU-US Privacy Shield (Article 45.1 of the GDPR); or
○ any other appropriate safeguards under article 46 GDPR.
6.2.2. If you are located within the EEA and wish to receive more information relating to the transfers of your personal information outside the EEA and/or the safeguards that have been implemented (including on how to receive a copy of these), you can contact us through the contact details set out in section 12 below.
6.3 In case your Personal Data is transferred outside of the People’s Republic of China, WABCO will undergo a risk assessment procedure to make sure that the risk associated with such transfer is justifiable.
7. Links to other websites
7.2 WABCO websites may contain links to other websites that are not owned or administered by WABCO. Please be aware that WABCO does not control and, consequently, is not responsible for the privacy practices of such other third party websites. We encourage you to read the privacy policies of every third party website you visit since their privacy practices may differ from those of WABCO.
8.1 We maintain reasonable safeguards to protect against unauthorized disclosure, misuse, alteration, or destruction of the personal information you provide to us through the WABCO websites. We protect data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies containing our confidential information, including your personal information. This protection may include in some locations entry-controls of the company, usage of lockable drawers and cupboards to protect personal information, destruction of the papers and digital storage devices including personal and/or sensitive information when they are no longer required. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. WABCO limits access to personal information to those persons in WABCO organization, or as third parties acting on behalf of WABCO, that have a specific business purpose for maintaining and processing such personal information. Individuals who have been granted access to personal information are aware of their responsibilities to protect the security, confidentiality, availability and integrity of that personal information and have been provided training and instruction on how to do so.
8.2 Please note, however, that perfect security does not exist on the Internet. Therefore, while we endeavour to protect your personal information, when data is transferred over the Internet it may potentially be accessed and used by unauthorized parties.
9. Retention of your personal data
- the processing of your information is necessary in connection with any actual or potential dispute (e.g. we need this information to establish or defend legal claims), in which case WABCO will keep your information until the end of such dispute; and/or
- the retention is necessary for WABCO to comply with any legal or regulatory obligation (e.g. for tax purposes), in which case WABCO will keep your information for as long as required by that obligation.
10. Your rights
10.1 You have certain rights regarding the information we hold about you. These rights include:
- the right to access the information we keep about you – we want you to be aware of the information we have about you and to enable you to verify whether we process your information in accordance with the applicable data protection laws and regulations;
- the right, under certain circumstances, to block or suppress further use of your information. When the processing is restricted, we can still store your information, but we can no longer use it;
- the right to request the rectification of your information, if your information is inaccurate or incomplete, ;
- the right, under certain circumstances, to request the deletion or removal of your information from our systems;
- the right to lodge a complaint about the way we handle or process your information with your national data protection authority;
- the right to withdraw your consent at any time, if our processing of your personal information is based specifically on that consent. This includes your right to withdraw consent to our use of your information for direct marketing purposes;
- the right to obtain from us, under certain circumstances, your information in a structured, commonly used and machine readable form so you can reuse it for your own purposes across different services. For example: if you want to work with a different service provider, this enables you to move your information easily and in a secure manner to this new service provider.
However, note that these rights are not absolute and even if you exercise these rights we may need to retain certain information, for example for legal or administrative purposes (e.g. keeping of accounting records).
10.2 If you would like to exercise any of the rights set out above, please send an email with “data privacy request” in the subject line to email@example.com and include a copy of your identity card or another proof of your identity (e.g. driver’s license) to help us prevent unauthorised individuals from accessing, changing or deleting your information. We will respond to your request as soon as practically possible. If we need more than one month (from receipt of your request) to respond to your request, we will come back to you and let you know.
12. Contact details
ZF CV Systems Europe BV
Chaussée de la Hulpe 166
Attention: Legal Department