The protection of your privacy rights when personal data is being processed is important to TRATON. Personal data collected when users visit our website is processed in accordance with the statutory provisions of the country in which the body responsible for processing the data has its legal domicile.
1. Collection of anonymous usage data
When you visit our website, our web servers store the IP address and the domain from which access is obtained, the date and time of the visit, the website that you visit with us and technical information on the visit (http method, http version, http status code, length of the transmitted data, browser used) as standard.
2. Collection and processing of personal data
Personal data will only be collected if you make said data available of your own accord, for example within the framework of registration, a survey or a sales promotion competition, or to implement a contract.
3. Earmarking of use and passing on of personal data
Your personal data will only be used for the purpose for which you have entrusted said data to us. Furthermore, no personal data will be passed on to third parties. Such data will only be passed on to government/state institutions and authorities within the framework of mandatory national legal provisions. Our employees have been bound by us to maintain secrecy and to protect personal data entrusted to us.
4. Right to withdraw consent
If you have consented to the use of your data for the receipt of company and product information in one of our applications, you can revoke your respective consent again at any time with future effect.
5. Right to information, right to correct
Upon request, TRATON will notify you in writing whether and which personal data pertaining to you is stored by us. If, in spite of our best endeavors to ensure the correctness and up-to-dateness of the data, incorrect information is stored, we will correct this information after receiving appropriate written instruction to do so.
TRATON uses technical and organizational security measures to protect your data so as to prevent accidental or deliberate tampering, loss, destruction or access by unauthorized persons. Our security measures, such as data encryption, are regularly improved in line with technological developments.
7. Links to websites of other providers
Our corporate website may contain links to websites of other providers. At the time the link was established, TRATON was satisfied that the directly linked pages were free of illegal content. However, TRATON has no influence whatsoever on the content of the linked pages and is unable to monitor these pages on a regular basis. TRATON therefore cannot be held liable for any content of the linked pages that has been changed since the creation of the link. This declaration concerning data protection does not apply to the linked websites of other providers.
In order to keep pace with the continuous development of the Internet, TRATON shall be entitled to adapt this declaration concerning data protection at any time whilst adhering to the provisions of legislation regarding data privacy protection.
10. Social plug-ins
So-called social plug-ins of social networks, such as Facebook, Instagram, YouTube, Twitter and Pinterest, are used in some areas of our website. The plug-ins can be identified by the logo of the respective social network.
As soon as you visit a website with an enabled social plug-in, your browser will establish, through the social plug-in, a direct connection to the servers of the social network in question and transmit data regarding your visit to the social network. Even if you are not a member of one of the social networks, there is a possibility that, through the social plug-in, said social network will find out certain data, such as your IP address, and perhaps save such data.
The social plug-ins on our website are therefore disabled by default. To use a social plug-in, you must enable it by clicking the corresponding button. As long as the social plug-in is not enabled, no data will be transmitted to the social network. After activation, the social plug-in connects to the servers of the social network, and will remain active until you disable it or delete your cookies (see “Cookies”). With the activation, a direct connection is established with the server of the social network in question. The content of the social plug-in is transmitted from the social network directly to your browser, which incorporates this into the website you visited. As such, we have no influence on the scope of the data collected by the social plug-in.
For more information regarding the purpose and scope of data collection along with the further processing and use of data by the respective social networks, your rights in this regard and the settings to protect your privacy, please refer to the social networks’ notices regarding data protection.
The following is a brief description of the social media plug-ins included on our site.
Twitter is a microblogging service of the U.S. company Twitter, Inc. (795 Folsom St., Suite 600, San Francisco, CA 94107). Through the Twitter button, your browser also establishes a direct connection to the Twitter servers and loads the button from there. Information is transmitted to Twitter that the corresponding website was accessed. Even if you are not logged in, Twitter can collect and store usage data as required. If you click on the Twitter buttons and tweet via the Twitter window that opens, you are submitting the information you tweet to Twitter. This information will be published in your Twitter user profile. For more information on data collection, analysis and processing of your data by Twitter, as well as your rights in this regard, please refer to http://twitter.com/privacy.
The protection of your personal rights during the processing of personal data is of the utmost concern to companies in TRATON Group (hereinafter referred to as "TRATON"). We process personal data in compliance with the provisions of the EU General Data Protection Regulation (GDPR) and in accordance with the legal regulations of the country in which the controller of the data processing is located.
Furthermore, TRATON companies have undertaken to provide comprehensive and uniform protection of personal data through the implementation of a binding Group policy. Within TRATON, this ensures a level of protection worldwide, which is comparable to that in Germany and the European Union. Moreover, our employees are obliged to maintain confidentiality with regard to the handling of personal data.
b) Controller and contact person
The controller as defined by data protection law is the TRATON company that processes your data as part of an existing or incipient contractual relationship. In the event of questions relating to data protection, please contact the data protection officer/data protection coordinator at the TRATON company with which you have or are initiating a contractual relationship. The ultimate holding company of TRATON Group is TRATON SE. Data Protection Officer of TRATON SE is Dr. Karl-Heinz Müller (Group Data Protection, Dachauer Straße 641, 80995 München, Tel: +49 89 36098-123, Fax: +49 89 36098-375, E-Mail: firstname.lastname@example.org).
a) Purpose limitation and legal basis
TRATON processes personal data in order to execute and manage an existing or incipient contractual relationship with you. In this context, your personal data is processed for various purposes as part of a range of processing activities.
b) Data sources
As a rule, your personal data is collected directly from you as part of an existing or incipient contract relationship.
c) Obligation to provide data
You must provide to the controller the personal data required to execute the contractual relationship. If you do not provide this data, TRATON cannot fulfil the relevant legal obligations and enter the contractual relationship.
d) Intended purpose of processing activities
An overview of the intended purpose of our processing activities is provided below:
Putting services and materials out to tender
Sending requests, calling in outstanding quotes, commercial review and completeness checking on quotes, and performing negotiations.
Order processing (materials and services)
Writing, submitting, sending, and tracking orders in the system.
Communication regarding products or services, responding to inquiries and requests, and bottleneck and risk management.
Procurement controlling and services provider controlling
Figures regarding suppliers and services provider.
Compliance with legal obligations
Compliance with retention obligations, ensuring that compliance requirements are met through checks (e.g. sanctions list checks and money laundering, references to legal infringements), operating an internal control system (ICS) and other monitoring systems for ensuring that business processes are in accordance with regulations.
The processed data can be classified into the following data categories:
The aforementioned processing activities are justified by the following legal bases:
In certain cases, your personal data may also be disclosed to other bodies: If the disclosure of your personal data is necessary in order to execute or initiate the contractual relationship. We will also disclose your personal data to service providers commissioned by us in the framework of order processing. Your core data and contact details are disclosed in a centralized database for the purpose of ensuring a current data stock and for credit checking. Other companies in TRATON Group are also able to access this database. If we are required to comply with country-specific legal requirements regarding the disclosure of your personal data, e.g. for transfer to financial authorities, courts, and auditors, we will fulfil this obligation.
We erase your personal data as soon as it is no longer required for the purposes stated above. Your personal data is stored for as long as we are required to do so by law, or for as long as statutory limitation periods apply. This regular arises due to legal obligations to provide proof and preserve records, governed by legislation including the Bürgerliches Gesetzbuch (BGB – German Civil Code), Handelsgesetzbuch (HGB – German Commercial Code), and the Abgabenordnung (AO – German Tax Code). Beyond this, data is only saved if there are further statutory or contractual storage obligations to do so.
You have the right to be informed about the data that relates to you, and the right to rectify your data. Provided that there are no statutory regulations to the contrary, you also have the right to erase your data and to object to the processing of your data, and the right to restrict the processing of your data. Furthermore, you have the right to data portability. If we collect and process your personal data on the basis of your consent, you also have the right to revoke the consent you granted with effect for the future. The legality of the data processing carried out with your consent until you revoke it, remains unaffected by your withdrawal of consent. If necessary, we need to verify your identity before we can process your requests. If, in spite of our efforts to maintain accurate and up-to-date data, incorrect information has been saved, we will correct such information upon corresponding request. In the event of complaints, there is the possibility to contact a data protection supervisory authority.
We do not perform automated individual decision-makings within the meaning of Art. 22 (1) & (4) of the GDPR.
TRATON uses technical and organizational security measures to protect your data against accidental or premeditated manipulation, loss and destruction, and access by unauthorized persons. Our security measures, such as data encryption, are regularly improved in accordance with technological development.
In order to avoid the risk of significant financial losses from fines, disgorgement and liability for damages, or criminal prosecution vis-a-vis TRATON Group or its employees, it is important that possible regulatory violations are identified at an early stage. Hints on potential regulatory violations can be reported via several channels within the TRATON Group.
When you report a hint, we process your personal data, when we receive, assess and investigate your hint in accordance with this data protection information.
Incoming hints are handled by a small group of expressly authorized and specially trained employees of TRATON SE’s Investigation Office (GOI) and are always treated confidentially. The TRATON Investigation Office checks the facts of the hint and, if necessary, conducts a further case-related investigation together with other investigation units or suitable bodies of the company concerned.
Confidentiality cannot be guaranteed if you deliberately submit false information with the aim of discrediting a person (denunciation).
Please read this privacy information carefully before submitting a hint. You can decide whether you want to submit an anonymous or non-anonymous hint.
The protection of your personal rights during the processing of personal data is of the utmost concern to TRATON SE. We process personal data in compliance with the provisions of the EU General Data Protection Regulation (GDPR) and in accordance with the national legal provisions.
Controller and contact person
The controller as defined by data protection law for the data processing relating to the acceptance, assessment and investigation of the hint is:
Dachauer Str. 641
which, in the context of the investigation process, acts in joint responsibility with the remaining group companies of Volkswagen Group according to Sec. 26 GDPR.
You can contact the data protection officer of TRATON SE via:
Dr. Karl-Heinz Müller
Dachauer Straße 641
Tel: +49 89 36098-123
Fax: +49 89 36098-375
TRATON SE processes your data for the following purposes:
Assessing and processing your hint and conducting necessary investigations associated therewith, against the affected person(s), and, where appropriate, for communication with authorities and courts in connection with your hint, communication with international attorneys and auditors or other investigating persons engaged by TRATON SE as well as other Group companies affiliated with TRATON SE.
Legal obligation to provide your personal data
You can report a hint without sharing your personal data (anonymous hint). You are therefore under no legal or contractual obligation to provide your personal data.
Type of personal data collected
We collect the following personal data and information when you report a hint:
The processing of your personal data is justified by the following legal bases:
In certain cases, your personal data may be transmitted to other recipients: In substantiated individual cases, while processing a hint, or as part of an investigation, it may be necessary to share information with other employees of TRATON SE or of other companies affiliated with TRATON SE, e.g. if the information relates to activities in TRATON SE’s subsidiaries. If required by the investigation, information can be shared with TRATON Group subsidiaries in a country outside the European Union or the European Economic Area, based on appropriate data protection guarantees designed to protect those affected (e.g. EU standard data protection clauses or other exceptional derogations according to Art 49 of the GDPR). We always ensure compliance with the relevant data protection provisions in connection with the disclosure of information.
In the event of a corresponding legal obligation or if TRATON SE or a third party has a legitimate interest in investigating the information, further possible categories of recipients are criminal prosecution authorities, antitrust authorities, other administrative authorities, courts as well as international attorneys and auditors engaged by TRATON SE or another Group company affiliated with TRATON SE.
In certain cases, TRATON SE is obliged by data protection legislation to inform the suspects of the charges made against them. This is a legal requirement in cases where it can be objectively established that the disclosure of information to the suspect can no longer have an adverse effect on the investigation in question. If you disclosed your name or other personal data (non-anonymous hint), your identity as a whistleblower will not be disclosed, as far as it is legally possible, and steps will also be taken to ensure that no conclusions can be drawn as to your identity as the whistleblower.
Personal data will be stored for as long as it is required for the purposes of the investigation and the subsequent assessment, and, in addition, as long as national legal, contractual or statutory retention periods obliges us to store.
Once the report has been processed, the data will be deleted or anonymized in accordance with the national legal requirements. In case of anonymization, the reference to your identity as a whistleblower is permanently and irreversibly removed.
In addition to the right to be informed about the data that relates to you, and the right to have your data rectified, you also have the right to demand erasure and restriction of processing (blocking) of your data collected for the aforementioned purposes, insofar as there are no legal provisions to the contrary. Furthermore, you have the right to data portability. If we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time (in case of a non-anonymous hint) with effect for the future. Your withdrawal does not affect the lawfulness of the collection and processing of your name based on your consent until then, nor does it affect the processing of your name on the basis of any other legal basis (e.g. law or legitimate interests). If we have already disclosed your data to authorities or courts, you must contact these authorities in order to assert your rights. If necessary, we need to verify your identity before we can process your respective request.
In the case of data protection breaches you have a right to contact a supervisory authority of your choice. A list of the data protection supervisory authorities of the German federal states as well as their contact data can be obtained via the link below:
To withdraw your consent (in case of a non-anonymous hint) or to exercise your rights regarding your data, please contact data-protection-vwtb@man or:
MAN T&B SE, Bereich FIO, Zentralteam Datenschutz, Dachauer Straße 667, 80995 Munich.
In case of other questions, please refer to the Investigation Office email@example.com or TRATON SE, Dachauer Straße 641, 80995 Munich.
Information on the right of objection against the processing of your personal data pursuant to Art. 21 Section 4 in conjunction with Section 1 GDPR
You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data which is necessary to safeguard our legitimate interests or the legitimate interests of a third party. Please kindly address your objection and the reasoning to:
or for postal delivery to the following address:
MAN T&B SE, Bereich FIO, Zentralteam Datenschutz, Dachauer Straße 667, 80995 Munich
We will assess whether we are obliged to delete your data due to your objection on the basis of the reasons given by you. Please note that a further processing of your personal data might be necessary despite your objection. This is the case, when compelling legitimate grounds prevail your interests, rights and freedoms or if we have to assert, exercise or defend legal claims. We will inform you about the result of our assessment.
We are pleased that you are visiting our Facebook fan page (hereinafter referred to as "fan page") of TRATON SE, Dachauer Straße 641, 80995 Munich, registered in the commercial register of the Munich Local Court under the number HRB 246 068. In the following, we inform you about the collection, processing and use of your data
The fan page you visit gives you the opportunity to react to our contributions, to comment on them, to create your own user post and to send us private messages with personal concerns. The data provided by you in this context and which may be accessible to us (e.g. Facebook user name, pictures, interests, contact data) will be used by us exclusively for the purpose of customer and prospective customer communication due to a predominant legitimate interest (Art. 6 Para. 1 lit. f GDPR). Our interest lies in offering you a platform on which we can display current information and with the help of which you can address your request to us and we can respond to your request as quickly as possible. As far as possible, your data will be deleted when the fan page operation is discontinued.
You may assert your following rights against TRATON SE at any time free of charge, insofar as this is possible for TRATON SE within the framework of the provision of fan pages. For the enforcement of further rights, please contact Facebook Ireland Limited, 4 Grand Canal Square, Dublin2, Ireland.
For information on exercising your rights with TRATON SE, please refer to Section f.
Right of access: You have the right to obtain information from us about the processing of your personal data.
Right to rectification: You have the right to ask us to rectify any inaccurate or incomplete personal data concerning you.
Right to erasure: You have the right to demand the erasure of your data if the conditions specified in Art. 17 GDPR are met. Thereafter you may, for example, request the erasure of your data insofar as they are no longer necessary for the purposes for which they were collected. You can also request erasure if we process your data on the basis of your consent and you revoke this consent.
Right to restriction of processing: You have the right to demand restriction of the processing of your data if the requirements of Art. 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. For the duration of checking the correctness of the data, you can then demand that the processing be restricted.
Right to object: If the processing is used in an overriding interest or your data is used for the purpose of direct marketing, you have the right to object to the processing of your data. An objection is permissible if the processing is either in the public interest or in the exercise of official authority or due to a justified interest of MAN SE or a third party. In the event of objection, we ask you to inform us of the reasons for which you object to data processing. In addition, you have the right to object to data processing for direct marketing purposes. This also applies to profiling as far as it is related to direct advertising.
Right to data portability: If data processing is based on consent or fulfilment of a contract and this is also carried out using automated processing, you have the right to receive your data in a structured, common and machine-readable format and to transfer it to another data processor.
Right of withdrawal: If the data processing is based on a consent, you have the right to withdraw the data processing within the scope of a consent with effect for the future at any time free of charge.
Right of complaint: You also have the right to complain to a supervisory authority (e.g. the Bavarian State Office for Data Protection) about our processing of your data.
The contact persons for the exercise of your rights and further information can be found on the following website https://traton.com/en/data-protection.html.
Our Data Protection officer is available to you as a contact for data protection-related concerns: