Kongsberg Automotive privacy policy
Privacy policy for visitors of the website, customers, distributors, suppliers and partner contacts
KA Group AG, with its registered address at Europaallee 39, 8004 Zurich Switzerland,(“Kongsberg Automotive” “we”, “our” and “us”), is controller for the processing of your personal data[1] as described below. Kongsberg Automotive GmbH, with its registered address at Zeppelinstrasse 4, Hallbergmoos DE-853 99, Tel. +49 811 99 86 78 0, Email: reception-hbm@ka-group.com is the representative established in the European Union.
We care and value your privacy. Through this privacy policy we therefore wish to provide you with information on how we process your personal data as well as what rights you have in relation to our processing of your personal data in your role as representative of our current or potential customers, distributors, suppliers or partners and when you visit our websites.
We process your personal data for the following purposes:
- to communicate with you;
- to administrate and negotiate any agreements with the company you represent;
- to enable you to create and use your customer account;
- to send newsletters you have subscribed to;
- to improve our website by analysing your feedback and your use of our website; and
- to comply with our legal obligations.
A more detialed description of each personal data processed, the legal basis for the respective processing and each retention periods can be found in the further below section “Detailed description on how we process your personal data”.
Hereinafter when we, in this privacy policy, refer to “your company” we refer to your employer or the company that you represent.
Below you can read more about how we process your personal data when you interact with us in different situations. Should you have any questions regarding our processing of your personal data, or if you wish to exercise any of your rights under data protection legislation, please contact us via our e-mail address specifically designated for this purpose gdpr@ka-group.com.
From where do we collect your personal data?
We collect your personal data directly from you, for example when you contact us. We may also collect your personal data directly from your organisation, if they state you as their representative. If you use our website, we will also use Google services to collect information on your browsing of our website to analyse your use of our website.
Are you required to provide personal data to us?
If your company purchase products from us we may need to process your personal data, e.g. in order for us to comply with legal obligations to which we are subject. In any other case you are free to choose if you wish to provide your personal data to us.
Who can gain access to your personal data and why?
Your personal data is primarily processed by us at Kongsberg Automotive. However, in certain instances, we may share your personal data with third parties as described below.
- We will share your personal data with our IT-suppliers who will process these on our behalf and on our instructions in order to ensure good and secure IT-operations. We only share your personal data with our IT-suppliers if it is necessary in order for them to fulfil their contractual obligations towards us.
- When necessary to process an order your company has made we share your personal data with other companies within the Kongsberg Automotive group of companies.
- We may share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests in accordance with applicable data protection legislation.
- We use a third party (Google) which on our behalf and on our instructions analyse the use of our website and therefore will access your personal data.
- If you interact with us or visit our pages on Facebook, Instagram, Twitter and LinkedIn the social media platform that you use will also process personal data about you as a user. These social media platforms are either processing your personal data on our instructions or as controllers in their own right for their processing of your personal data. What role they have in a particular case depends on the specific platform and activity. Please refer to the section “Detailed desciption on how we process your personal data” for more information.
If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.
Where are your personal data processed?
We, as well as our processors, mainly process your personal data within EU/EEA. In certain instances, we will process your personal data outside of the EU/EEA according to below.
- We will transfer your personal data outside the EU/EEA if it is necessary for us to fulfil our part of the agreement with the company you represent. For instance, if you work in a country outside the EU/EEA, we will transfer your personal data to that country.
- We may also transfer your personal data outside the EU/EEA to our IT suppliers that process the personal data on behalf of us as processors. The IT suppliers provide cloud services and/or perform IT-support and maintenance for us and the purpose of the transfer is for us to receive their assistance and/or use the service.
- In order to share your personal data with companies within the Kongsberg Automotive group of companies for the purpose of processing customer’s or distributor’s orders and complaints. In that case your personal data is stored where the companies are located. In order to protect your personal data during this transfer we have entered into an intercompany agreement for the sharing of personal data and have as well entered into a set of standard contractual clauses including supplementary measures. The latter is a model contract decided by the European Commission to provide sufficient safeguards on data protection for the personal data when transferred internationally. You may request a copy of relevant excerpts of the intercompany agreement by contacting us at gdpr@ka-group.com.
- We use Google who processes personal data outside of the EU/EEA to analyse the use of our website. If you use our website, we will therefore store your personal data outside of the EU/EEA. Please refer to the section “Detailed description on how to process your personal data” for more information.
If your personal data is according to the above or otherwise transferred to a third party or group company in a country outside the EU/EEA, Kongsberg Automotive will always take suitable and appropriate safeguards to protect the personal data being processed. This means we will only transfer your personal data outside the EU/EEA where there is an adequate safeguard for doing this under the General Data Protection Regulation (GDPR), either if the transfer of your personal data is done to a country that the European Commission has approved as providing an adequate level of protection for personal data, or if the transfer is based on the European Commission approved standard contractual clauses including supplementary measures. A copy of these standard contractual clauses can be obtained under https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914.
If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.
What rights do you have in relation to our processing of your personal data?
According to applicable data protection legislation, depending on the circumstances, you are entitled to a number of different rights which are set out below.
If you have any questions regarding these rights or if you want to use any of your rights, you are welcome to contact us. Our contact details can be found in the beginning of this privacy policy.
Right to information and access – You have the right to obtain a confirmation on whether or not we process your personal data. If we process your personal data, you also have a right to receive information about how we process the personal data and to receive a copy of your personal data.
Right to withdraw consent – If you have given your consent to us to process your personal data to send you newsletter you have a right to, wholly or partly, withdraw any given consent for the processing of your personal data with effect for the future.
Right to object -You have the right to object to our processing of your personal data if we use it for marketing purposes.
You also have a right to object to our processing of your personal data when the processing is based on the legal basis “legitimate interest”. The situations when we base our processing on our legitimate interest are stated in the below charts and you can read more about our balancing of interest assessments in the end of this privacy policy. In some instances we may continue to process your personal data even if you have objected to our processing. This can be the case if we can show compelling legitimate reasons for the processing that outweigh your interests or if our processing is necessary for the purpose of establishing, exercising or defending against legal claims.
Right to rectification – You have a right to have inaccurate personal data corrected and to have incomplete personal data completed.
Right to erasure (“right to be forgotten”) and restriction of processing – You have the right to have your personal data erased in certain instances. This is the case e.g. when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, or you withdraw your consent on which the processing is based and where we process your personal data on the basis of our legitimate interest and we find, following your objection (see below under Right to object), that we do not have an overriding interest in continuing to process it.
You also have a right to request that we restrict our processing of your personal data. For example, when you question the accuracy of the personal data, when you have objected to our processing of your personal data based upon our legitimate interest, or where the processing is unlawful, and you oppose to the erasure of your personal data and instead want us to restrict our processing.
Right to data portability – You have a right to in certain instances be provided with such personal data (concerning you) that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to in certain instances have such personal data transferred to another controller, where technically feasible.
Right to lodge a complaint to a supervisory authority – You have the right to lodge a complaint to a supervisory authority concerning our processing of your personal data.
Such a complaint can be filed to the authority in the EU/EEA member state where you live, work or where the alleged infringement of applicable data protection legislation has occurred.
Detailed description on how we process your personal data
The below charts describes in detail why we process your personal data, which personal data we process, the legal basis for the processing and for how long we process your personal data.
If you have contacted us before we have a relationship with your organisation
| Why do we process your personal data? | What personal data do we process? | What is the legal basis for the processing? | How long do we store your personal data? |
|---|---|---|---|
| To communicate with you who have contacted us via e-mail or telephone. | Name, telephone number, e-mail address and other personal data that you provide to us. | Art. 6 para. 1 s. 1 a) GDPR our legitimate interest to process your personal data to communicate with you or your organisation, Art. 6 para. 1 s. 1 f) GDPR. | We will store your personal data for as long as the matter is unresolved. |
If your company is our current customer, distributor or supplier
| Why do we process your personal data? | What personal data do we process? | What is the legal basis for the processing? | How long do we store your personal data? |
|---|---|---|---|
| To negotiate and enter into an agreement with your organisation. To administrate our relationship with your company (e.g. communicate with our customer, distributor or supplier and process any order our customer or distributor has placed). | Name, organisational belonging, position in your organisation, telephone number and e-mail address. If you represent a customer or distributor: Information about the order your company has made. | To process your personal data to be able to negotiate and enter into an agreement with your company and to administrate the agreement, Art. 6 para. 1 s. 1 b) GDPR. | Your personal data will be removed if we conclude that we not will enter into an agreement with your organisation. If your company becomes our customer, distributor or supplier we will store your personal data for this purpose as long as the company you represent are our customer/distributor/supplier, however for a shorter period of time if we get information that you no longer represent the organisation. |
| If you represent a customer or distributor: To create and enable your company to create an account, including to communicate with you. To give your company the benefits of having an account, i.e. to enable you to place an order. | Name, organisational belonging, e-mail address, username and password. | Our legitimate interest to process your personal data to provide your organisation’s account, to administer such an account and to give your company the benefits of having an account, Art. 6 para. 1 s. 1 f) GDPR. | We will store your personal data for as long as your company is our customer or distributor, however for a shorter period of time if we get information that you no longer represent your organisation. You can delete your organisation’s account whenever you want. If you do so, we will immediately stop storing your personal data for this purpose. |
| If you represent a customer or distributor: To comply with bookkeeping and accounting law. | Name, history regarding payments made and other information that constitutes accounting records. | The processing is necessary to comply with legal obligations to which we are subject, i.e. the bookkeeping and accounting act, Art. 6 para. 1 s. 1 c). | We will store your personal data until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates or as long as relevant bookkeeping and accounting laws requires. |
| To handle complaints or other claims. To defend ourselves against claims and complaints. To initiate any claims. | Name, organisational belonging, position at your organisation, telephone number, e-mail address and information concerning the complaint or claim. | Our legitimate interest to process your personal data to handle a complaint and/or legal dispute in relation to your organisation, Art. 6 para. 1 s 1 f) GDPR. | We will store your personal data until we have processed the complaint and for the duration of the potential dispute. |
If you have chosen to subscribe to our newsletter
| Why do we process your personal data? | What personal data do we process? | What is the legal basis for the processing? | How long do we store your personal data? |
|---|---|---|---|
| To send newsletters that you have subscribed to. | Name and e-mail address. | Your consent, Art. 6 para. 1 s. 1 a) GDPR. | We will store your personal data until you unsubscribe or of we do not use your data for more than two years. We will store information to prove receipt of consent for three years after the end of the year of your withdrawal of consent. |
If you use our website
| Why do we process your personal data? | What personal data do we process? | What is the legal basis for the processing? | How long do we store your personal data? |
|---|---|---|---|
| To enable and analyse the use of our website. | Information which we collect through cookies, i.e. IP-address, personal data related to your devise/browser (from which area in the country you reside in that you use our website from and which screen resolution you have) and your activities on our website. | The processing is necessary to enable your use of our website, takes place in accordance with Art. 6 par. 1 s. 1 b) GDPR, and our legitimate interest to process your personal data to improve our website in order to improve the user experience of our website, Art. 6 par. 1 s. 1 f) GDPR. | We will store your personal data for a period of six months after your visit to our website, IP addresses are anonymized after 24 hours at the latest. |
| To analyse and improve our website based on the information we have compiled through using Google Analytics. | IP address, type and version of your Internet browser, operating system used, the page accessed, the previously visited page (referrer URL), date and time of access, frequency of page visits, unique ID for (re-)recognition of returning visitors, which is stored on the user's terminal device by means of a cookie (we use cookies for the Google Analytics web analysis tool), information about the use of the website, in particular page impressions, frequency of calls and length of stay on called-up pages with assignment to the unique visitor ID of the respective visitor contained in the Google Analytics terminal device data; region/location of visit. | Your consent, Art. 6 para. 1 s. 1 a) GDPR. | On our website a so-called IP anonymization is activated. This means that the IP address transmitted by the browser for technical reasons is anonymized by shortening the IP address before storage. We store the remaining data for 24 months. Google processes this data for a period of 14 months, unless you delete cookies on your terminal device, in which case the processing ends with the deletion. |
We use Google Analytics to get an overview of the behaviour of website visitors, and gain insights regarding our digital marketing efforts. Google Analytics also helps us, for example, understand user demographic characteristics such as age, gender and interests, geographic characteristics such as language and location, as well as technical characteristics. Such data gives us a good overview of our website and how it is used. Even if we collect user data, we cannot draw any conclusions about the identity of the website visitor from this data, as we receive reports from Google Analytics that are based on aggregated data sets.
Google Analytics is provided to us by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes the website usage data on our behalf and is contractually committed to measures to ensure the security and confidentiality of the processed data. Google may transfer personal data, in particular the IP address and the Google ID in the US where the privacy laws do not provide for an adequate protection compared to the EU. Regardless of where your information is processed, Google applies the protections described in its privacy policy at https://policies.google.com/privacy, and comply with certain legal frameworks relating to the transfer of data, such as adequacy decisions and European Commission approved standard contractual clauses. To enable Google Analytics, we use cookies.
Please refer to our our cookie policy here to receive further and more detailed information on cookies and functionalities we use on our website.
If you interact with us on our social media accounts
| Why do we process your personal data? | What personal data do we process? | What is the legal basis for the processing? | How long do we store your personal data? |
|---|---|---|---|
| To communicate with you on our social media accounts (Facebook, Instagram, Twitter and LinkedIn), e.g. if you comment on a post, and to keep records of such communication for reference. | Information from your profile on the social media in question (user name and any picture you have chosen for your account) and information which you provide on our page. | Our legitimate interest to process your personal data to communicate with you on our social media platforms, Art. 6 para. 1 s. 1 f) GDPR. | Your personal data will be removed if you ask us to remove it or if you yourself delete the content, but we will otherwise store the personal data on the social media platform until further notice. |
If you click on a link embedded in our website, you will be redirected to the respective page: Facebook: https://www.facebook.com, Instagram: https://www.instagram.com, LinkedIn: https://de.linkedin.com, Twitter: www.twitter.com. Plugins of these social networks are integrated on our website. When you visit our website, a direct connection between your browser and the server of the social network is established via the plugins. The social network thereby receives the information that you have visited this website with your IP address. If you are logged into your account with the social network, the social network can assign the visit to this website to your user account. Details on data collection (purpose, scope, further processing, use) as well as your rights and setting options can be found in the privacy policy of the social network. The deletion of your personal data by the social network takes place as described in the respective privacy policy. If there is joint responsibility with Instagram or Facebook, the contract on joint responsibility applies. You can find the contract at https://de-de.facebook.com/legal/terms/page_controller_addendum. For more information on the respective responsibilities, please refer to the Facebook Page Insights Supplement (https://de-de.facebook.com/legal/terms/page_controller_addendum). Your personal data is transferred to the companies listed below in the USA or can be accessed from there. Information on data processing can be found at:
Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland) – Privacy Policy/Opt-Out: https://www.facebook.com/about/privacy/legal_bases.
Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/Opt-Out: http://instagram.com/about/legal/privacy.
Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization.
LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Clicking on a link to Facebook, Instagram, Twitter or LinkedIn, will take you to the respective websites of the different providers. Data processing on the respective website is governed by the data protection information applicable there.
Balancing of interests assessments when processing personal data based on the legal basis “legitimate interests”
As we state above, for some purposes, we process your person
al data based upon our “legitimate interest”. By carrying out a balancing of interests assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data.
If you want more information in relation to our balancing of interests assessments, please do not hesitate to contact us. Our contact details can be found at the beginning of this privacy policy.
[1] Personal data is any information that can be used directly or indirectly to identify you, such as your name or telephone number.
Kongsberg Automotive adopted this privacy policy on May 10, 2019.