Webasto Data
Privacy

1. Controller

1.1 Webasto SE ("Webasto"), Kraillinger Straße 5, 82131 Stockdorf, Germany, is responsible within the meaning of Art. 4 No. 7 of the General Data Protection Regulation ("GDPR"). 

1.2 For more information about us, please refer to our legal notice. You can contact our data protection officer, Mr. Manfred Gerlach, at dataprotection@webasto.com or by telephone on +49 (89) 8 57 94 - 0.

2. General information

The following statement gives you an overview of what kind of personal data is collected, for what purpose and on what legal basis. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behavior. We also inform you about your rights vis-à-vis us as the controller.

3. Data processing on this website

3.1 When using this website for information purposes only, we automatically collect and store information that your browser transmits to us in the server log files. 

• IP address
• Date and time of the request
• Time zone different to Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status/http status code
• The amount of data transferred in each case
• Website from which the request comes
• Browser, operating system and its interface
• Language and version of the browser software

3.2 This data is technically necessary for us to display this website to you and to ensure stability and security. The temporary storage of the IP address by the system is necessary to enable the website to be delivered to your computer. For this purpose, your IP address must remain stored for the duration of the session. 

3.3 Data is collected and stored in log files to ensure the functionality of the website. We also use the data to optimize the website and to ensure the security of our information technology systems. 

3.4 The legal basis for the collection and temporary storage is § 25 para. 2 no. 2 TTDSG i.V.m. Art. 6 para. 1, sentence 1, lit. f) GDPR. Our legitimate interest pursuant to Art. 6 para. 1, sentence 1, lit. f) GDPR lies in the abovementioned purposes. 

3.5 This data is stored on servers in the European Union. They are deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, this is the case after 12 months at the latest.

3.6 The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation and delivery of the website. Consequently, the user has no option to object. 

4. Further data processing on our website

In addition to the collection and storage of log files, other personal data is processed on our website. You can find out below what  data is involved, for what purposes and on what legal basis we process it.. 

4.1 Consent processing system (Usercentrics)

4.1.1 Webasto uses a consent processing system from the provider Usercentrics to implement your usage preferences according to your wishes. 

4.1.2 Data collected through the consent processing system:

• Opt-in and opt-out data
• Referring URL
• User agent
• User settings
• Consent ID
• Date of consent
• Type of consent
• Version of the template 
• Language of the banner
• IP address
• Geographical location

4.1.3 The legal basis for the processing of personal data using the consent management tool is the fulfillment of a legal obligation pursuant to Art. 6 para. 1, sentence 1, lit. c) GDPR and § 25 para. 2 no. 2 TTDSG.

4.1.4 The data is stored and processed in the European Union (Belgium). 

4.1.5 We process your personal data for these purposes only for as long as is necessary to achieve the purpose and generally for no longer than 14 months. In addition, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it.

4.2 Content management solution (Adobe Experience Manager)

4.2.1 Webasto uses a comprehensive content management solution from Adobe to create websites, mobile applications and forms.

4.2.2 Data collected by the content management solution:

• Usage data
• IP address
• Information on the content
• Content or placed advertising
• Geographical location

4.2.3 The legal basis for the use of the Adobe Experience Manager is your consent Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG.

4.2.4 The data is stored and processed in the European Union. 

4.2.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.2.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html.

4.2.7 We process your personal data for these purposes (i) until you withdraw your consent with effect for the future or (ii) for as long as this is necessary to achieve the purpose, but generally no longer than 14 months. Beyond this, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it.

4.3 Tag Management (Adobe Launch)

4.3.1 Webasto uses a tag management system from Adobe to manage the analysis, marketing and advertising tags used.

4.3.2 The tag management tool itself does not process any personal data. However, the information processed via the tool is shared with Adobe.

4.3.3 The legal basis for the use of Adobe Launch is your consent in accordance with Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG. 

4.3.4 The data is stored and processed in the European Union. 

4.3.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.3.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html. 

4.3.7 If the separately listed tags, which are processed via tag management, transmit personal data, this data is forwarded to Adobe.

4.3.8 Information is only stored for the duration of the web session. 

4.4 Adobe Experience Cloud Identity Service

4.4.1 Adobe Experience Cloud Identity Services is used to identify users with multiple sessions. This is used to check and verify the identity, as well as to identify the web session.

4.4.2 User preferences, account settings, identifiers, online identifiers and cookie identifiers are processed for this purpose.

4.4.3 The legal basis for the use of Adobe Experience Cloud Identity Services is your consent in accordance with Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG.

4.4.4 The data is processed in the European Union. 

4.4.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.4.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html.

4.4.7 We process your personal data for these purposes (i) until you withdraw your consent with effect for the future or (ii) for as long as this is necessary to achieve the purpose, but generally no longer than 14 months. In addition, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it

4.5 Web analysis service (Adobe Analytics)

4.5.1 Webasto uses Adobe Analytics software for realtime analysis and detailed segmentation across all marketing channels.

4.5.2 Adobe Analytics processes the following data from you:

• Success rates of advertising campaigns
• Browser information
• Click path
• Clicked advertising
• Cookie ID
• Date and time of the visit
• Device information
• Information that users provide in forms on this website
• IP address
• ISP/connection speed
• Items added to the shopping cart
• Name of the website
• Personal information provided by the user outside the services
• Product information, such as colors, prices, styles and photos
• Purchase activity
• Referring URL
• Search query when the user clicks on the link to this page
• Usage data
• Whether the user has clicked on a link, an image or a text
• Whether the user has downloaded a file, an image or something else

4.5.3 The legal basis for the use of Adobe Analytics is your consent in accordance with Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG.

4.5.4 The data is processed in the European Union. 

4.5.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.5.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html.

4.5.7 The data is kept for a period of 14 months from the time of the survey.

4.6 User analysis (Adobe Audience Manager)

4.6.1 Webasto uses Adobe Audience Manager to identify visitors to our pages and to analyze their activities when they visit our pages, to record data calls, synchronize data, track errors and carry out tests.

4.6.2 Adobe Audience Manager processes the following information:

• Device information
• HTTP header
• IP address
• Referring URL
• Browser information

4.6.3 The legal basis for the use of Adobe Audience Manager is your consent in accordance with Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG.

4.6.4 The data is processed in the European Union. 

4.6.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.6.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html.

4.6.7 We process your personal data for these purposes (i) until you withdraw your consent with effect for the future or (ii) for as long as this is necessary to achieve the purpose, but generally no longer than 14 months. In addition, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it

4.7 Other IT services

4.7.1 Webasto uses Adobe's Everesttech service to provide additional IT services, such as payment processing, website security, analysis and customer support. 

4.7.2 Everesttech processes the following information:

• Data provided via forms on the website
• Information about the device
• IP address
• Referring URL
• Search query when the user clicks on the link to this page
• Usage data
• Browser information

4.7.3 The legal basis for the use of Everesttech is your consent in accordance with Art. 6 para. 1, sentence 1, lit. a) GDPR and § 25 para. 1 TTDSG.

4.7.4 The data is processed in the European Union. 

4.7.5 You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our Consent Manager or by clicking the "Unsubscribe" button at www.adobe.com/de/privacy/opt-out.html.

4.7.6 Information from the third-party provider: Adobe Systems Software Ireland Limited, Ireland, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland; privacy@adobe.com; Privacy Policy: www.adobe.com/de/privacy/policy.html.

4.7.7 We process your personal data for these purposes (i) until you withdraw your consent with effect for the future or (ii) for as long as this is necessary to achieve the purpose, but generally no longer than 14 months. Beyond this, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it.

5. Contact us

5.1 There is a contact form on our website that can be used to contact us electronically. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored. These data are

• Salutation
• Title
• First name
• Last name
• Company
• Address
• E-mail address
• Phone number
• Type of request
• Your message to us
• Interest in (product, product group, business unit, sales, support, technical support)
• City
• Zip code
• Country

5.2 The following data is also stored at the time the message is sent:

• IP address
• Browser information
• Usage data
• Date and time of the visit
• Pages accessed
• Device information
• Demographic data

5.3 For the processing of the data, your consent is first obtained before sending and reference is made to this privacy policy. The legal basis for the processing in this case is Art. 6 para. 1, sentence 1, lit. a GDPR. 

5.4 Alternatively, it is possible to contact us via the e-mail address provided. In this case, the personal data of the user transmitted with the e-mail will be stored. The legal basis for the processing of the data transmitted in the course of sending an email is Art. 6 para1, sentence 1, lit. f GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1, sentence 1, lit. b) GDPR.

5.5 The processing of the personal data from the input mask serves us solely to process the contact. If contact is made by email, this also constitutes the necessary legitimate interest in processing the data. The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

5.6 The data is used exclusively for processing the contact. For this purpose, they are stored in Webasto's CRM system. 

5.7 To provide the CRM system, Webasto uses the service provider ClickDimensions LLC, 6849 Peachtree Dunwoody Road, Bulding B-1, Suite 200, Sandy Springs, GA 30328, United States of America, as a processor to transfer the data to Webasto's CRM system.

5.8 As a CRM system, Webasto uses Microsoft Dynamics 365 for Sales from the service provider Microsoft Corporation Dept. 551, Volume Licensing 6880 Sierra Center Partway Reno, Nevada 89511 USA as a processor. 

5.9 We process your personal data for these purposes (i) until you withdraw your consent with effect for the future or (ii) for as long as this is necessary to achieve the purpose, but generally no longer than 14 months. In addition, we only store personal data for the assertion of or defense against legal claims or as long as there are legal obligations to store it

5.10 Data subjects have the option of withdrawing their consent to the processing of personal data at any time. If data subjects contact us, they can object to the storage of their personal data at any time. In such a case, we will not be able to continue processing your request. You can send your objection to the following address: dataprotection@webasto.com

All personal data stored in the course of contacting us will be deleted in this case. 

6. Cookies

6.1 Furthermore, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard disk and assigned to the browser you are using and through which certain information flows to the body that sets the cookie (in this case us). This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. Cookies cannot execute programs or transmit viruses to your computer. 

6.2 Below you will find a list of the cookies we use:

7. Webasto in the social media

7.1 In addition to this website, we are also present on various social media. We are currently represented on Twitter, Xing, LinkedIn, Facebook and Instagram. Our profiles can be accessed via the links on the website.

7.2 Your personal data may be processed by the respective service providers on their websites, over which we have no influence. 

7.3 The purpose and scope of data collection as well as the provisions on the use of personal data by the respective platform can be found in the data protection provisions of the respective operator, e.g.

Twitter: https://twitter.com/privacy

Xing: https://privacy.xing.com/de/datenschutzerklaerung

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Facebook: https://www.facebook.com/privacy/policy

Instagram: https://privacycenter.instagram.com/policy/

Further information on data processing by us and the respective platform can be found in our privacy policy for social media.

8. Recipients: Processors and other controllers

8.1 As described above in this data protection information, we sometimes work together with other companies in order to be able to use or offer certain functions and services. These are either processors with whom we have concluded a data processing agreement within the meaning of Art. 28 GDPR, or other controllers such as other Webasto Group companies. 

8.2 If we disclose your personal data to other controllers who process the personal data not on our instructions but for their own purposes, this will only be done for specific purposes. The transfer of your personal data to these other controllers for these purposes is carried out for the performance of a contract, Art. 6 para. 1, sentence 1, lit. b) GDPR or on the basis of our legitimate interest (Art. 6 para. 1, sentence 1, lit. f) GDPR) in the efficient operation of our business.

8.3 Otherwise, we only transfer your personal data to other data controllers if and insofar as this is required by law in order to enforce legal claims or to investigate or prevent suspected or actual unlawful circumstances. In these cases, we will inform you separately about the respective transfer if and insofar as this is legally required.

8.4 If we transfer your personal data to processors or other controllers in countries outside the European Economic Area (EEA) (e.g. in the USA), we implement the legally required standards and security mechanisms. 

9. Your rights

9.1 Right to information: As we only collect data from and about you to the extent described above, we only have information about you from the use of our website if you have contacted us and provided us with the relevant information. You can assert your right to information in writing or by e-mail to us (see legal notice). 

9.2 Right to revoke the declaration of consent under data protection law: If the processing of your data is based on your consent, you have the right to revoke this consent at any time in accordance with Art. 7 para. 3 GDPR. The revocation does not affect the legality of the processing carried out up to that point. You can declare your revocation in writing or by e-mail.

9.3 Right to rectification: If your personal data is incorrect, you have the right to request its rectification (Art. 16 GDPR).

9.4 Right to restriction of processing: Under the conditions of Art. 18 GDPR, you have the right to request that the processing of data concerning you be restricted.

9.5 Right to erasure: Under the conditions set out in Art. 17 GDPR, you have the right to request the erasure of personal data concerning you. This is the case, for example, if you withdraw your consent or if the data is no longer required for the purposes for which it was collected.

9.6 Right to lodge a complaint: If you are of the opinion that the processing of your personal data violates data protection regulations, you have the option of contacting us or lodging a complaint with the supervisory authority responsible for us:

Bavarian State Office for Data Protection Supervision

Promenade 18, 91522 Ansbach

Phone: +49 (0) 981 180093-0

Fax: +49 (0) 981 180093-800

E-mail: poststelle@lda.bayern.de

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

9.7 Right of objection:

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. We will no longer process the personal data concerning you unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Our privacy policy may change from time to time. This also includes further developments due to changes in our business as well as adjustments due to changes in the legal situation and/or due to the implementation of new technologies or services on the website. We will publish any corresponding updates to the privacy policy on this page.

If you have any further questions that our privacy policy could not answer, please send an e-mail to the following address dataprotection@webasto.com

Status: November 2023