Privacy Notice
This privacy notice applies to your use of ContiConnect On-Site via the application (Application).
This privacy notice aims to give you information on how Continental collects and processes your personal data through your use of the ContiConnect On-Site and Application, including any data you may provide through the use of the ContiConnect On-Site and Application.
1. Who is responsible for the data processing?
Continental Reifen Deutschland GmbH (“Continental” or “we” or “us”) is the controller and responsible for your personal data.
The contact details are:
Continental Reifen Deutschland GmbH
- Data Protection Officer -
Continental-Plaza 1
30175 Hanover - Germany
Tel/Fax: +49 511 938-01
E-mail: dataprotection@conti.de
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated in March 2024.
Functioning of ContiConnect On-Site
a) Installation of ContiConnect On-Site
Use of the ContiConnect On-Site requires the installation of the Application and your consent to the Terms of Use.
b) Registration of ContiConnect On-Site
Use of the ContiConnect On-Site requires registration in the ContiConnect WebPortal (Portal), by stating your first and last name and choosing a password. For the purpose of honest and fair dealing with each other you are requested to provide true information: your real name, email address and work phone number. You will first receive a user-ID as username within the registration process; you are free to change your password later. Furthermore, you have to give your prior consent to the Terms of Use and this privacy notice.
c) Usage of ContiConnect On-Site
Use of the Application requires the installation of it on a smartphone / device.
In order to use the Application, as part of a ContiConnect system, the data is also made accessible on the Portal (please see the privacy notice on the Portal for further information on how your data is processed when you use the Portal).
Additionally:
-
the Application must be activated;
-
you must be logged in;
-
you must have been signed-up, set up and maintained in the Portal;
-
the smartphone / device you use should be set to allow
localisation services, for the vehicle inspection service (localisation
services are switched off by default. You have the possibility of switching on
the localisation services); and
-
the collection of Continental tyre sensor data
(e.g. tyre temperature, tyre pressure) is done by enabling Bluetooth.
The Application allows the transmission to Continental only of your personal data and your vehicle and tyre sensor data necessary to fulfil the services by Continental detailed under section 3 of the Terms of Use. There is no exchanging of personal or other data as between you and other users of the Application.
d) Tokens
When you use the Application, information can be stored on your mobile phone in the form of a token. Tokens are only technically necessary to ensure the operation of the Application. Tokens are used after you login in the Application and as soon as you log out the tokens are deleted. The Application uses two types of tokens:
Access token
· This is an authorisation token and it’s used to validate your login information and grants you access to your data. Your name, email and location are processed.
· Duration of storage: As long as you are logged in.
· Tracking function: No.
Refresh token
· This communicates with Center Authentication Services (CAS authentication provider) and refreshes the access tokens after it expires.
· Duration of storage: As long as you are logged in.
· Tracking function: No.
2. Which personal data is processed?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
-Identity Data: Name (first name and last name), username.
-Contact Data: Email and phone number.
-Technical Data: Date and time of the use of the Application, time zone setting and location data (including the location of any smartphone used at the time of the vehicle inspection), internet protocol (IP) address, device token for push notifications and other technology on the devices you use to access the Application.
-Profile Data: includes your username and password.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
In the event that the Application crashes, a report is automatically generated, and we transmit the data to the following service providers: Google Firebase Crashlytics (Crashlytics).
The Application uses Crashlytics, a crash reporting tool from Google Inc. (“Google”). Crashlytics collects certain information, in order to help identifying the root cause of any occurring crash. This data can among others contain device state information, device identifiers, such as hardware and operating system (OS) information, information relating to how the Application functions at the time of a crash. Additionally, it can contain information about how you use the Application.
The collected information belongs to Continental and is used to get insight into the functionality and the problems which occur during runtime.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or in order for us to provide the ContiConnect On-Site and Application to you, and you fail to provide that data when requested, we may not be able to provide the ContiConnect On-Site and Application.
3. How is your personal data collected?
Your personal data is collected when you directly interact with us, when you create an account and use the ContiConnect On-Site and Application.
4. For what purposes and on which legal basis is your data processed?
Personal data entered by you is collected, processed and used by Continental Reifen Deutschland GmbH for the purpose of providing the services provided by the ContiConnect On-Site and Application, as well as user authentication and access validation.
The Application displays tyre related data (e.g. tyre pressure, tyre temperature) of a connected Continental tyre sensor, to a mobile device and provides warning signals and recommendations as soon as a tyre related alert occurs. Furthermore, the Application allows the transmission of tyre, vehicle and quality- related data into the Application backend and to make this data available for the Application.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Please refer to the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
|
Data Processing (Purpose) |
Type of data |
Legal Basis |
|
To register you as a new Application user and allow you to access and use the ContiConnect On-Site and Application. |
(a) Identity (b) Contact (c)Profile |
(a) Performance of a contract (b) Legitimate Interests (to enable us to provide you with access to the Application) |
|
To manage our relationship with you which will include: (a) Responding to you (any questions/queries raised etc.). (b) Notifying you of changes to the Application. (c) Notifying you about changes to our Terms of Use or this privacy notice. |
(a) Identity (b) Contact (c) Profile |
(a) Performance of a contract (b) Necessary for our legitimate interests (to keep our records updated and to respond to you to enable you to use/access the App) |
|
To administer and protect our business and the Application including troubleshooting, data analysis and system testing. |
(a) Identity (b) Contact (c) Profile (d) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
|
To use data analytics to improve the service and Application. |
(a) Technical |
Necessary for our legitimate interests (to develop the products/services and grow our business) |
CHANGE OF PURPOSE
5. To which categories of recipients is your personal data transferred?
We may share your personal data with the parties set out below, for the purposes set out in the table above.
Internal Third Parties
We may share your personal data with other entities in the worldwide group of companies of which Continental forms.
External Third Parties
We share your personal data with below external third parties.
|
Sub-processor (Company Name, Address) |
Subject matter |
Location of data center / processing |
|
T-Systems International GmbH, Hahnstrasse 43D, 60528 Frankfurt/Main, Germany |
Hosting |
EU |
|
Amazon Webservices EMEA SARL |
Hosting |
EU |
|
Azure |
Hosting |
EU |
|
MessageBird B.V. |
SMS |
EU |
|
Questar Auto Technologies LTD 1st Aba – Even St. Herzeliya, 4672519, Israel |
Telematics |
EU |
|
Cloudera, Inc. 5470 Great America Parkway Santa Clara CA 95054, US |
Hosting |
EU |
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We also may share your personal data if we think we have to in order to comply with the law or to protect ourselves. If necessary, we share the data to respond to a court order or subpoena, or in response to a government agency or investigatory body request. We share with any successor to all or part of our business. If all or part of our business is sold, we may share the personal data as part of that transaction. If there is a merger or acquisition, we may also share your personal data. If there is a financing or bankruptcy, we may share your personal data.
How long will the data be stored?
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
6. Is data transferred to countries outside the EU / EEA?
Continental is based in Germany, therefore your data is shared outside the UK, but within the EEA.
We may also share your personal data within the Continental Group. This will also involve transferring your data outside the UK/EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see Binding Corporate Rules.
Some of our external third parties are based outside the UK/EEA so their processing of your personal data will involve a transfer of data outside the UK/EEA.
In addition to the use of Binding Corporate Rules, whenever we transfer your personal data out of the UK/EE, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government. For further details, see International transfers | ICO; or
· For transfers to external third parties, we may use specific contracts as issued by the Information Commissioner’s Office under Section 119A Data Protection Act 2018or as approved by the European Commission which give personal data the same protection it has in the UK and Europe. These specific contracts currently include the International Data Transfer Agreement (IDTA) and the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses (Addendum) for the UK and Standard Contractual Clauses (SCCs) for the EEA. For further details, see International data transfer agreement and guidance | ICO (for UK) and Standard Contractual Clauses (SCC) | European Commission (europa.eu) (for EEA/EU).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or access in an unauthorised way, altered or disclosed and our company uses technical and organisational security measures to protect the personal data you provide to us.
The security measures are continuously improved and adapted. Unencrypted data can possibly be viewed by third parties. For this reason, we would like to point out that no secure transmission can be guaranteed with regard to data transmission via the Internet (e.g. when communicating by unencrypted e-mail). Sensitive data should therefore either not be transmitted at all or only via a secure connection (SSL). You can determine the SSL status of the connection by looking at the address line of your browser ("https").
7. Which Rights of the data subject(s) do you have?
Once you have provided your personal data, you have several rights, which you can exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the following rights in connection with the processing of your personal data:
· Right to revoke your consent at any time
If and to the extent we collect and/or process any of your personal data based on your consent, you will be able to withdraw your consent at any time you choose and at your own initiative. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your personal data based on your consent up until the moment where you withdraw your consent.
If you wish to withdraw your consent, a notification (marked for the attention of the Data Protection Officer) must be made in writing either by post to the address set out below, or by email to info@conticonnect.com.
Continental Continental Reifen Deutschland GmbH,
Continental-Plaza 1, D-30175 Hannover, Germany.
· Right of access by the data subject
You have the right to access and review your personal data. You may be entitled to ask us for a copy of your information, to review or correct it. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Right to rectification
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Right to erasure
You have the right to erasure of your personal data processed by us in case it is no longer needed for the purposes for which the personal data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Declaration and no other legal ground for processing applies. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Right to restriction of processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios (i) if you want us to establish the data's accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Right to data portability
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Right to object at any time
Under certain circumstances you may object to the processing of your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Right to lodge a complaint with a supervisory authority
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues in the UK (www.ico.org.uk) or any other supervisory authority.
We would, however, welcome the opportunity to deal with your concerns in the first instance, and will work towards addressing any issues or complaints that you may have.
If you have any questions in this about the privacy notice or wish to exercise any of your rights, please feel free to contact our data protection officer: dataprotection@conti.de.
8. Closing Provisions
Continental may make changes or amend this privacy notice.
In each case of intended change to this privacy notice Continental shall give reasonable notice to you prior to any change coming into force. Such notification shall take place via email to the email address provided by you upon registration or via pop-up window in case a registration was not required.
If we do change or amend this privacy notice, you may have to give consent to continue to use of the Application by ticking the respective opt-in box of the pop-up window.
Supplement For California Users
In the Privacy Notice we have provided an overview of the types of personal data collected and processed, how your personal data is used, with whom your personal data is shared, and other general details regarding our processing activities associated with your use of the Application. This Supplement contains additional details for Application users who are resident in California. If you are a California resident, this Supplement applies.
Pursuant to the California Consumer Privacy Act of 2018, as amended, and its implemented rules and regulations (collectively, “California Privacy Laws”), in the Privacy Notice and this Supplement we provide a summary of the personal information that we have collected from you, the sources from which we have collected the personal information, the business purposes for which the personal information was collected, and the categories of third parties with whom We share Your Personal Information. Under California Privacy Laws, you may have specific rights.
We do not “sell” or “share” your Personal Information, as those terms are defined under California Privacy Laws.
Changes: We may update this Supplement from time-to-time. The current Supplement will be effective when posted. Please check this Supplement periodically for updates. When required under applicable law, we will notify you of any changes to this Supplement by posting an update on the respective Teams end user support channel. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle personal data previously collected from you. If you do not provide such consent, personal data will continue to be used in a manner that is consistent with the version of this Supplement under which it was collected.
Categories of Personal Information Continental Collects
The types of personal information that Continental has collected about you during your registration and use of the Application, and any use of the Service during the preceding 12 months are:
· Identifiers, such as your name, alias, username, user identification or unique personal identifier, internet protocol address, email address, phone number, and vehicle identification number (“VIN”), as applicable.
· Information related to your interactions with and use of the Application, such as your login/access history, session information, and other information regarding your interactions with us through the Application.
· Professional and employment information, such as your employer’s name, business address, or other professional information.
· Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
· “Sensitive Personal Information”, as such term is defined under applicable data protection laws, including:
· Specific geolocation information, such as location-based information from your mobile device, either continuously or while you are using the Application (you may wish to restrict collection of this information by modifying Your device’s settings).
Note that the above list is broad simply to capture the types of information required for different types of interactions between us. Not all of the above information is captured during each interaction.
Special Note Regarding Sensitive Personal Information
Sources of Personal Information
We collect Personal Information and other information about you and how you interact with us in several ways, including:
· Information you provide to us directly. We collect the information you provide to us directly.
· Information automatically collected or inferred from your interaction with us. We automatically collect technical information about your interactions with us (such as time spent using the Application, features accessed or used in the Application, geolocation, and other details), as well as from your interactions with Continental representatives and agents.
· Special Note about information collected from or generated by your mobile device. Use of the Application requires access or permission to certain features of your mobile device, including location services. If you wish to restrict our access or permissions, you may do so in your device’s settings. Restricting our access may negatively impact your use of the Application.
· Information from third parties. We may receive information about you and your interactions with us from third parties, such as from your employer or coworkers, representatives, third party service, and others interacting with us and/or using Continental services.
We may combine information that we receive from the various sources described in this Privacy Policy, including third party sources and public sources, and use or disclose it for the purposes identified below.
We may use each your Personal Information in the following ways and for the following business purposes:
· To Provide the Application and Enable Interactions Between You and Continental.
· For Our Internal Business Purposes. Continental may use your Personal Information for our internal business purposes related to providing, supporting, and administering the Application. This includes, but is not limited to, evaluating or auditing the usage and performance of Service, programs and technologies related to interactions with us; evaluating and improving the quality of your interactions with us and the Service, programs and technologies related to interactions with us; designing new services; processing and cataloging your responses to surveys or questionnaires (e.g., customer satisfaction reviews); performing internal research for technological development and demonstration; conducting data analysis and testing; maintaining proper business records and other relevant records.
· For Auditing Purposes. Auditing related to current interactions with employees and concurrent transactions.
· For Legal and Compliance Purposes. Legal compliance requirements, compliance training, investigating and responding to claims against Continental and its agents and personnel, due diligence purposes (like in connection with a corporate transaction), and other related purposes.
· For Security Purposes. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity, environmental, health and safety, including monitoring and maintaining the security of the working environment with security cameras, maintenance of medical and sickness records and occupational health programs, keeping emergency contacts, behavioral safety, and statutory reporting obligations.
· For Debugging Purposes. Debugging to identify and repair system, network and equipment errors that impair existing intended functionality of Continental’s systems, networks, and devices.
· To Enable Performance of Supporting Services. Continental may use your information to allow it and certain 3rd parties to perform services its behalf, or in relation to the administration of our relationship with you. This may include logistics, promotional and marketing services, development and training, IT administration of our technologies, network, and intranet, and IT security management and tasks.
· For Quality Assurance. Undertaking activities to verify or maintain the quality or safety of, and to improve, upgrade, or enhance, our services, products, and premises. This may include certain recordkeeping, such as accounting, commercial, procurement, document management and other similar activities. This may also include certain reporting functions like financial information and financial background checks, and consultancy and advisory services.
· For Marketing Communication. In accordance to the acceptance of the Marketing Purposes on ContiConnect Lite register form.
Disclosure of Your Personal Information
We disclose all the categories and types of personal information that we collect in the Types of Personal Information Continental Collects section to all recipients identified Privacy Notice for the business purposes set forth in How CTA Uses Your Personal Information.
Your Rights
California residents have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information. California residents may exercise the following rights via emailing us at [email protected] , by calling (833) 656-0555 or by using our webform: https://www.continental-tires.com/us/en/b2b/truck/contact/privacy-rights-request/ .
California residents have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information. California residents may exercise the following rights via emailing us at privacy@continental.com or by calling (833) 656-0555.
· Right to Know. You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, the categories of third parties with whom we have shared your Personal Information, and the purpose for which we shared your Personal Information (“Categories Report”). You may also request information about the specific pieces of Personal Information we have collected about you (“Specific Pieces Report”).
· Right to Correct. You may have the right to request that we correct inaccurate Personal Information that We maintain about You.
· Right to Delete. You have the right to request that We delete Personal Information that We have collected from You.
We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights. We will not discriminate against You, in any manner prohibited by applicable law, for exercising these rights. Notwithstanding the foregoing, the foregoing rights may not apply in all instances, and We may deny Your request where we have a legitimate basis to do so.
Verification
In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above. We will use commercially reasonable verification techniques, designed to balance the need to ensure we are not providing your information to someone pretending to be you, while at the same time not making it too difficult for you to exercise your rights.
Authorized Agents
You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify you as described above or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent.
Timing
We will respond to Requests to Delete and Requests to Know within 45 days, unless we need more time in which case we will notify you and may take up to 90 days total to respond to your request.
Appeal
If we deny your rights request, you may have the right to appeal. To submit an appeal, privacy@continental.com. We will inform you in writing our response to your appeal.
This Version of the Policy is Effective as of May 27, 2024.