Privacy statement

 

(Version of: 23/11/2020)

We, the “Alltrucks GmbH & Co. KG”, are pleased that you are visiting our website and are interested in our company. In the following Privacy Statement, we would like to inform you in particular about how we process your personal data as well as about your rights in this regard.

 

Section 1 Controller

“Controller” within the meaning of Article 4(7) of the EU General Data Protection Regulation (GDPR) is

Alltrucks GmbH & Co. KG

represented by the Managing Director Homer Smyrliadis

Perchtinger Str. 6, 81379 Munich, Germany

Email: data.protection@alltrucks.com

Phone: +49 (0)89 4622466 - 0

Fax: +49 (0)89 4622466 – 86

(hereinafter ALLTRUCKS” or “we”).

 

Section 2 Data protection officer

You can contact our data protection officer at:

BBH AG Wirtschaftsprüfungsgesellschaft

Pfeuferstraße 7

81373 Munich, Germany

Phone: +49 (0)89 23 11 64 – 244

Email: datenschutz@bbh-online.de

Please also feel free to contact our main point of contact for matters of data protection via email at: data.protection@alltrucks.com

 

Section 3 Information on the processing of personal data

We process personal data only if and to the extent that this is permissible under the applicable provisions regarding the protection of personal data or if you have given us your consent to do so.

“Personal data” means any information relating to an identified or identifiable natural person. Personal data may include, for example, name, address, email address, phone number and bank details.

Further terms used in this Privacy Statement shall (also) have the meaning set forth in the definitions under Article 4 GDPR.

For more detailed information on the processing of data when visiting our website (server logs), please see no. 1 below. Under nos. 2 to 6 of this section 3 you will find information on the further processing of data which only takes place if you provide us with additional personal data on a voluntary basis. There will, in essence, not be any negative effects for you if you do not provide us with personal data in addition to the data specified under no. 1 above. In individual cases, however, we, in our capacity as controller, need your personal data in order to be able to act, e.g. to be able to process an enquiry from you. In such cases, we cannot provide the service you request without using the personal data required for this purpose.

None of the data processing activities listed in the following involves automated decision-making including profiling within the meaning of Article 22(1) and (4) GDPR.

 

1. Processing of data when visiting our website (server logs)

When you visit our website (including our partner portal and our Alltrucks fleet platform), we automatically collect the data transmitted by your browser to our server in order to make access to our website technically possible. To ensure the security and stability of our website, our web server automatically logs every access to our website. In this context, the following information is collected:

•              IP address of the requesting computer,

•              Date and time of the server request,

•              File names and URL/web address that you have accessed,

•              Access status /http status code,

•              Volume of data transmitted,

•              Referrer URL (i.e. the website you have previously accessed),

•              Browser,

•              Operating system and its interface as well as

•              Browser software version and language.

Your information is evaluated for statistical purposes and stored on our servers for seven (7) days. ‎If the above information contains references to individuals, the legal basis for its processing is Article 6(1) first sentence lit. (f) GDPR, as we have a legitimate interest in processing the data for the purpose of ensuring the security and stability of our website.

2. Data processing when using a contact form

We have embedded various contact forms in our website. You can use these contact forms (e.g. if you want to become a partner workshop) in order to contact us electronically and send us an enquiry or provide us with information. If you fill in such a contact form and provide us with your data using the respective button, the data you enter in the respective contact form will be transmitted to us. We process these (personal) data in order to process or respond to your enquiry and/or contact you.

The legal basis for the processing, for the above mentioned purpose, of your personal data which you provide to us by submitting your enquiry via contact form is your consent to such processing and thus Article 6(1) first sentence lit. (a) GDPR.

In principle, we store the data processed by us via the contact form for as long as this is necessary for the achievement of the relevant purpose. Should you withdraw your consent prior to the achievement of such purpose, we will, upon receipt of the withdrawal of consent, no longer process your data for such purpose and will erase them.

 

3. Data processing in the context of a workshop contract with an Alltrucks partner

Alltrucks offers a full-service workshop concept across Europe under the brand “Alltrucks Truck + Trailer Service”. Under this workshop concept, Alltrucks offers workshops the opportunity to acquire special skills in the area of commercial vehicle systems and aims to establish a long-term partnership with these workshops (so-called Alltrucks partners). The following statements refer specifically to the processing of data in the context of such a workshop contract (including any amendments thereto).

We only process data provided to us within the context of the conclusion, performance and handling of the workshop contract. We do not process any personal data obtained from publicly accessible sources.

 

a) Categories of processed personal data

Within the context of the conclusion as well as the performance and handling of a workshop contract concluded with an Alltrucks partner, we process the following categories of personal data:

  • Identification data and contact details of the Alltrucks partner (e.g. customer number, company name and/or name, address) as well as content and circumstances of the communication within the context of the initiation, performance and handling of the contract
  • Information on the Alltrucks partner’s business premises (e.g. company name, address, equipment, condition, performance category)
  • Billing data (e.g. bank account details) and data on the payment behaviour
  • Content of contracts (e.g. distribution contracts, agreements on purchasing objectives) with third parties and signature on the contracts
  • Contact details and professional title or position of the contact persons at the Alltrucks partner (e.g. name, business email address, telephone number)

 

b) Purpose of and legal basis for the processing of personal data

We process the categories of personal data listed above for the following purposes and on the following legal bases:

aa)      On the basis of consent (Article 6(1) first sentence lit (a) GDPR)

If you have given us your consent to do so, we process the personal data on the basis of Article 6(1) first sentence lit (a) GDPR for the purpose covered by the declaration of consent.

bb)      For the performance of contractual obligations (Article 6(1) first sentence lit. (b) GDPR)

We process the personal data for the purpose of the conclusion, performance and handling of the workshop contract between Alltrucks and the Alltrucks partner including any amendments thereto as well as in order to take steps necessary prior to entering into a contract within the meaning of Article 6(1) first sentence lit. (b) GDPR). This includes, in particular, the following:

  • Performance of the contractual obligations by Alltrucks (e.g. access to offers from Alltrucks, sending of internal and market information, advertising for Alltrucks-specific services provided by the Alltrucks partner)
  • Processing of the data of the contractual partner on the Alltrucks portal
  • Enabling participation in and running the Alltrucks training courses
  • Ensuring compliance of the Alltrucks partner with the Alltrucks’ minimum requirements

cc)       Based on a legitimate interest (Article. 6(1) first sentence lit. (f) GDPR)

We process the personal data on the basis of Article 6(1) first sentence lit (f) GDPR for the purposes of our legitimate interests, i.e.

  • for processing and responding to general enquiries which are not directly related to the conclusion, performance and handling of the workshop contract,
  • for promoting the Alltrucks umbrella brand and the presentation of Alltrucks’ offers by the local Alltrucks partners to (potential) customers and members of the Alltrucks fleet, in particular through publication on the Internet (e.g. on the “Alltrucks Workshop Finder”),
  • for strengthening the exchange within the network of Alltrucks workshops by making the data available to other Alltrucks partners (e.g. on the partner portal),
  • for storing the data of the administrator as well as contact persons of the Alltrucks partner on the Alltrucks portal, for providing the (contact) data of these persons on various media (e.g. in the “Alltrucks Workshop Finder”) and for the provision of certain services (e.g. technical information and training) by Alltrucks,
  • for the simplified granting or activation of licences by entering data into the relevant licensing services/tools,
  • for the conclusion, performance and handling of an existing contract with an Alltrucks partner if personal data are processed that do not concern the contractual partner,
  • for providing information (e.g. about new cooperation partners) and for promotional purposes (e.g. information about special offers, services and the portfolio of cooperation partners or shareholders of Alltrucks),
  • for documenting cases of warranty claims,
  • for providing the services to the Alltrucks fleet customers

 

c) Recipients/categories of recipients of personal data

Personal data processed within the context of the conclusion, performance and handling of the workshop contract are disclosed to the following recipients or categories of recipients:

  •    External service providers (IT service providers (e.g. for the programming and adjustment of the Alltrucks portal and applications); service providers who work for us to ensure a pan-European service network (e.g. for the technical hotline, 24-hour breakdown service); owner of the training centre, if applicable)
  •    Preferred partners/ cooperation partners of Alltrucks
  •    Shareholders of Alltrucks (Robert Bosch GmbH, Knorr-Bremse Systeme für Nutzfahrzeuge GmbH, ZF Friedrichshafen AG)
  •    Other members in the Alltrucks workshop network
  •    Members of the Alltrucks fleet

 

d) Transfer of personal data to or within third countries or to international organisations.

The personal data processed within the context of the workshop contract are, in principle, not transferred to any international organisations. Personal data are only transferred to third countries in the context of the forwarding of data to partner workshops in the Alltrucks workshop network as described under c) below. In this respect, Alltrucks shall ensure that the level of data protection required under the GDPR is met in the third countries covered by the Alltrucks workshop network. For this purpose, Alltrucks shall make sure that the data are processed in a third country for which an adequacy decision of the European Commission has been adopted or that there are appropriate safeguards in the respective third country ensuring an adequate level of protection of personal data in accordance with the GDPR.

 

4. Data processing in the context of the Alltrucks partner portal

In the following, we would like to inform you about the data processing when registering on and using the Alltrucks partner portal.

 

a) Registration on the Alltrucks partner portal

Our contractual partners may draw on our services online. To access these services, our contractual partners need to register and designate employees that are granted access to the online services. In the context of the registration process, the users are informed about the mandatory data which are processed on the basis of Article 6(1) first sentence lit. (f) GDPR for the purposes of registration on the Alltrucks partner portal, provision of such data on the user account and protection against their misuse.

 

b) Editing a user profile

If, after previously registering on the Alltrucks partner portal, you edit your user profile data (personal information and/or contact details as well as data regarding the company), we process the personal information transmitted to us via the respective button. The legal basis for the processing of personal data of the contractual partner for the purpose of enabling access to the partner portal and editing the user profile data is Article 6(1) first sentence lit. (b) GDPR. The legal basis for the processing of personal data in other cases is Article 6(1) first sentence lit. (f) GDPR, as we have a legitimate interest in enabling the access to the partner portal and in the requested adjustment of the user profile data on such portal.

 

c) Training portal

If you use our training programmes and book a seminar via our training portal, we process the data transmitted to us in the context of the registration for the seminar for the purpose of the conclusion, performance and handling of the contract on the respective seminar. The legal basis for the processing of personal data of the contractual partner is Article 6(1) first sentence lit. (b) GDPR. Where the seminar participant is not a contractual partner, the legal basis for the processing of the participant’s personal data is Article 6(1) first sentence lit. (f) GDPR as we have a legitimate interest in enabling participation in the seminar/training.

The data transmitted to us in the context of the registration for the seminar are disclosed to the provider of the seminar/training indicated on the registration form.

 

d) Data processing within the framework of the Alltrucks VINcat parts catalogue

For more detailed information on the processing of personal data in relation to the license agreement concerning the Alltrucks VINcat parts catalogue, please see the information sheet on data protection which is available at https://internal.alltrucks.com/documents/10180/701972/Datenschutzinformationen+zum+EULA_Bestellschein_Alltrucks_VINcat/36d34675-564d-4b01-b004-540e3e71346e.

 

e) Data processing within the context of the Alltrucks job portal

For more detailed information on the processing of personal data within the context of the Alltrucks job portal/ job market, please see the respective privacy notice available at https://www.alltrucks-jobmarket.com/en/node/107.

 

5. Data processing within the framework of the fleet service programme “Alltrucks Fleet”

Within the framework of the workshop concept, Alltrucks offers the so-called “fleet service programme” for “fleet partners”. Under this programme, the partners are provided with a comprehensive package of services within the online platform established for this purpose regarding the organisation and performance of repairs and maintenance of the commercial vehicles (fleet vehicles) by the Alltrucks partners. The fleet partnership is established and becomes legally binding through registration on the Alltrucks fleet platform in conjunction with the signing of the user agreement by the fleet partner and Alltrucks. We process personal data within the context of the initiation and performance of the contract regarding the fleet service programme with Alltrucks as well as within the context of the use of the Alltrucks fleet platform.

These data are disclosed to the following categories of recipients: workshops and service providers that provide services which are booked on the Alltrucks fleet platform.

 

a) Alltrucks fleet partners

If a fleet partner concludes or intends to conclude a contract on the use of the fleet service programme “Alltrucks Fleet” and the related Alltrucks fleet platform, the data provided within the context of the registration process and/or the initiation and performance of the contract (including the use of our online platform) (i.e. company information and contact details of the contact person, service and fleet information (such as e.g. number plate and VIN-Code)) are processed for the purpose of the conclusion, performance and handling of the aforementioned contractual relationship with a fleet partner as well as to facilitate communication and, respectively, interaction between fleet partner and Alltrucks partner.

The data are stored on our Alltrucks fleet online platform. Upon successful registration and log-in on the platform, it is then possible to view and manage, among others, account data, settings and services.

The legal basis for the processing of personal data of the contractual partner is Article 6(1) first sentence lit. (b) GDPR. Apart from that, the legal basis for the processing of personal data is Article 6(1) first sentence lit. (f) GDPR as we have a legitimate interest in the processing of these data for the purpose of facilitating communication via our online platform as well as in increasing the quality of services for our contractual partners and expanding the range of our services.

 

b) Alltrucks partners (workshops)

If an Alltrucks partner intends to participate in the fleet service programme “Alltrucks Fleet”and use our online platform, the data provided within the context of the registration process and/or the initiation and performance of the contract (including the use of our online platform) (i.e. company information and contact details of the contact person, service information) are processed for the purpose of the conclusion, performance and handling of the respective contractual relationship with an Alltrucks partner as well as to facilitate communication and, respectively, interaction between fleet partner and Alltrucks partner.

The data are stored on our Alltrucks fleet online platform. Upon successful registration and log-in on the platform, it is then possible to view and manage, among others, account data, settings and services.

The legal basis for the processing of personal data of the contractual partner is Article 6(1) first sentence lit. (b) GDPR. Apart from that, the legal basis for the processing of personal data is Article 6(1) first sentence lit. (f) GDPR as we have a legitimate interest in the processing of these data for the purpose of facilitating communication via our online platform as well as in increasing the quality of services for our Alltrucks partners and expanding the range of our services.

 

6. Processing of data in the context of requests to be contacted/enquiries

If you send us an enquiry by email (e.g. email address, name etc.) or contact us in any other way, we process, where necessary, personal data to be able to respond to such enquiry in the first place and to adequately deal with your enquiry according to its purpose. The legal basis for the processing of personal data submitted to us within the context of an enquiry is Article 6(1) first sentence lit. (f) GDPR as we have a legitimate interest in the processing of the data for the purpose of processing and responding to your enquiry. If your enquiry relates to the conclusion of a contract with us, the legal basis for the processing of personal data is Article 6(1) first sentence lit. (b) GDPR.

 

Section 4 Duration of the storage of personal data; retention obligations

In principle, your personal data are stored for as long as this is necessary for the achievement of the purposes for which the data are processed by us. This means that we store personal data in particular for as long as this is required to conclude, and perform as well as handle a contract, there is an overriding legitimate interest in the processing of data within the meaning of Article 6(1) first sentence lit. (f) GDPR, or until a previously given consent to the processing of personal data (Article 6(1) first sentence lit. (a) GDPR) is withdrawn. All contact details and further personal data which are/were processed within the context of existing contractual relationships with Alltrucks are erased after termination of our contractual relationship. This also applies to our partner workshops. For more detailed information on the duration of the storage of your personal data, please also see the individual bullet points in this Privacy Statement.

In addition, statutory requirements, in particular archiving obligations, may result in an obligation to retain data. Due to applicable legal provisions under commercial and tax law, we are obliged to retain certain data/documents for a period of six and, respectively, ten years. In such cases, we will, however, block access to your personal data so that these data can only be used for archiving purposes. In such a case, the legal basis for the processing of your personal data is Article 6(1) first sentence lit. (c) GDPR.

 

Section 5 Recipients/categories of recipients of personal data

We will not pass your personal data on to any third parties, except if we are legally authorised or obliged to do so or if you have given your consent to this.

Forwarding of personal data to any public bodies and/or public authorities shall only take place when we are required to do so by mandatory statutory provisions or official or judicial orders.

Your personal data will be disclosed to shipping service providers, breakdown service providers or technical service providers. For additional information on the categories of recipients within the context of the individual processing operations, please see the individual bullet points in section 3 above.

 

Section 6 Links to Google Maps

On our website, we use the services of Google Maps in order to show you locations, such as our company site, and make the planning of your routes more convenient.

In order to ensure that as little data as possible is collected when using Google Maps, we provide the mapping function of Google Maps only via a link to the website of Google Maps. This means that no data concerning you will be transferred to Google when you visit our website if you do not click the Google Maps link. However, as soon as you click the link we have placed to Google Maps, you will be forwarded to the website of Google Maps. We have no influence on the processing of data then carried out independently by Google.

For details regarding the purpose and scope of data collection and the further processing and use of the personal data by Google as well as your corresponding rights and setting options in order to protect your privacy, please see the respective provisions on data protection of Google (https://policies.google.com/privacy?hl=en).

Please note that clicking the link to Google Maps will cause you to leave the scope of protection and responsibility of our website and that activating the link will lead to Google collecting and processing data, which is not subject to our control.

 

Section 7 Links to social media networks via social media buttons

We have embedded various social media buttons in our website, in particular those of Facebook and LinkedIn. We use social media buttons in order to make our website more user-friendly.

We have integrated the social media buttons into our website as links. If you click one of these buttons, you will reach our profile on the respective social media network. If you do not click any of our social media buttons, no data will be transferred to the providers of these networks during your visit to our website. Your information will only be transferred to the respective provider of the (social media) network if you click one of our social media buttons and are thus forwarded to our online presence in the respective network.

We have no influence on the processing of your personal data by the respective providers of the plug-ins.

For details regarding the purpose and scope of data collection and the further processing and use of the personal data by the providers as well as your corresponding rights and setting options in order to protect your privacy, please see the respective provisions on data protection of the providers.

Please note that clicking one of the social media plug-ins will cause you to leave the scope of protection and responsibility of our website and that activating the plug-ins will lead to the individual providers collecting and processing your data, which is not subject to our control.

 

Section 8 Right to access, rectification, erasure, restriction of processing, data portability, withdrawal of a declaration of consent

You have, in principle, the following rights vis-à-vis us regarding your personal data:

  • Right to 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 and
  • Right to data portability pursuant toArticle 20 GDPR.

Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR) in line with section 9 below.

As regards the right to object pursuant to Article 21 GDPR, please see our explanations under section 10 of this Privacy Statement.

If you give your consent to the processing of your personal data, you have the right to withdraw your consent at any time. Please be advised that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

 

Section 9 Right to lodge a complaint with the data protection supervisory authority

If you believe that our processing of your personal data is not in compliance with the provisions described herein and/or the applicable data protection laws, you may lodge a complaint concerning our processing of your personal data with a data protection supervisory authority at any time (Article 77 GDPR). The competent data protection supervisory authority which is, in principle, responsible for us is: Bayerisches Landesamt für Datenschutzaufsicht, Promenade 27, 91522 Ansbach, Germany.

 

Section 10 Right to object

According to Article 21(1) GDPR, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data within the meaning of Article 6(1) first sentence lit. (e) or (f) GDPR. You may address your objection to the Controller (see section 1) or to our data protection officer (see section 2). In case of objection, we shall no longer use your personal data for the respective purposes and erase them from our systems, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or if processing is necessary to establish, exercise or defend legal claims.

 

Version of: 23/11/2020

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