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Data Protection

  • 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.

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    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. Purpose limitation 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 rectify
    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.


    6. Security
    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.


    8. Cookies
    Cookies are small text files which are placed on your computer and stored by your browser. Cookies do not cause any damage to your computer and do not contain any viruses. Most browsers are set to accept cookies automatically. You do, however, have the opportunity to deactivate this function in your browser. TRATON uses cookies to make its offers more user-friendly, more effective, and more secure. Our cookies do not contain any personal information. The cookies we use are so-called “session cookies.” They are deleted automatically at the end of your visit. Naturally, you can also view our website without cookies. This may, however, impair the way our offers work.


    9. Reservation
    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 data protection legislation.


    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 said social network will use the social plug-in to 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' information on data protection.

    The following is a brief description of the social media plug-ins included on our site.


    Twitter
    Twitter is a microblogging service of the US 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.


    YouTube
    We use YouTube to embed and stream videos on our website. YouTube videos on this website are embedded in privacy-enhanced mode. YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Content is only downloaded via YouTube if you consent to this when you first visit our website or explicitly before starting the video. Whenever you visit a page on our website that has a video embedded on it via a YouTube plug-in, your browser connects to YouTube servers. This is used to send information to YouTube about the pages you have visited. Further information may be sent to YouTube, some of which may also be transferred to the US or other third countries. You starting the video may result in further data being processed. We have no control over this. If you are already signed in to YouTube when you visit our website, YouTube will also assign this information directly to your personal user account. If you interact with the plug-in, for example click the play button, this will also be assigned to your YouTube account. To avoid this happening, you have to sign out of your YouTube account before using our website. The YouTube privacy policy and further information on the data it processes can be found at https://policies.google.com/privacy. Information on YouTube cookies can be found at https://policies.google.com/technologies/cookies and further information on cookies used on our website at https://traton.com/en/cookies.html.


    Podcast — BEBE Medien GmbH
    This website uses content (podcasts) from the third-party provider BEBE Medien GmbH (BEBE Medien GmbH, Erich-Zeigner-Allee 69-73, 04229 Leipzig, Germany). Content is only downloaded via BEBE Medien GmbH (feeds.podcastproduzenten.de) if you have consented to this when you first visit our website or explicitly before starting the podcast. The following information is processed by BEBE Medien GmbH within this context:

    • IP address of requesting computer
    • Date and time of request
    • Name and URL of file accessed
    • Website from which access was initiated (referrer URL)
    • Browser used and, if applicable, your computer’s operating system, as well as the name of your access provider
    The information above is used to make the podcast available and to guarantee the stability and security of the servers and systems of BEBE Medien GmbH. The information transmitted to BEBE Medien GmbH when the podcast is played is not processed any further beyond this scope.


    11. Controller and point of contact


    TRATON SE
    Dachauer Str. 641
    80995 Munich, Germany


    To contact the Data Protection team or to exercise your data subject rights, please use the contact form.


  • 1. General information

    a) Introduction
    The protection of your privacy rights during the processing of personal data is important to companies in the 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 that 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 point of contact
    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 the TRATON GROUP is TRATON SE (TRATON SE, Dachauer Straße 641, 80995 Munich, Germany). To contact the Data Protection team or to exercise your data subject rights, please use the contact form.


    2. Collection and processing of personal data

    a) Purpose limitation and legal basis
    TRATON processes your 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 contractual 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 or enter into 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 check of quotes, and performing negotiations.


    Order processing (materials, services)
    Writing, submitting, sending, and tracking orders in the system.


    Supplier support
    Communication regarding products or services, responding to inquiries and requests, and bottleneck and risk management.


    Procurement controlling and service provider controlling
    Figures regarding suppliers.


    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 comply with regulations.


    The processed data can be classified into the following data categories:

    • Professional contact and (work) organizational data
    • IT usage data
    • Data on personal/professional circumstances & characteristics
    • Creditworthiness and bank data
    • Contractual data

    The aforementioned processing activities are justified by the following legal basis:

    • Consent to one or more specified purposes (point (a) of Article 6(1) of the GDPR)
    • Fulfilment of the contract or contract initiation (point (b) of Article 6(1) of the GDPR)
    • Fulfilment of legal obligations (point (c) of Article 6(1) of the GDPR)
      • Balancing of interests (point (f) of Article 6(1) of the GDPR)
      • The existence of a relevant and appropriate relationship between the controller and the data subject
      • Prevention of fraud
      • Direct advertising
      • Transfer of data within a corporate group for internal management purposes (including customer and employee data)

    3. Transfer of personal data

    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 also disclose your personal data to service providers commissioned by us within the framework of order processing. Your core data and contact details are disclosed for the purpose of ensuring an up-to-date database and for credit checking. Other affiliated companies of the 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, or auditors, we will fulfil this obligation.


    4. Data retention and erasure

    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 regularly 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.


    5. Your rights

    You have the right to be informed about the data that relates to you and the right to have your data rectified. Provided that there are no statutory regulations to the contrary, you also have the right to have your data erased 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.


    6. Automated decision-making

    We do not perform automated individual decision-making within the meaning of Article 22(1) & (4) of the GDPR.


    7. Security

    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 the TRATON GROUP or its employees, it is important that possible regulatory violations are identified at an early stage. Information regarding potential regulatory violations can be reported via several channels within the TRATON GROUP.

    When you submit a tip-off, we process your personal data when we receive, assess, and investigate your tip-off in accordance with this information on data protection.

    Incoming tip-offs are handled by a small group of expressly authorized and specially trained employees of TRATON SE’s GRC Investigation Office (GOI). The TRATON Investigation Office checks the facts of the tip-off and, if necessary, conducts a further case-related investigation together with other investigation units of the company concerned. Tip-offs are always treated confidentially.

    Confidentiality cannot be guaranteed if you deliberately submit false information with the aim of discrediting a person (denunciation).

    Please read this information on data protection carefully before submitting a tip-off. You can decide whether you want to submit an anonymous or non-anonymous tip-off.


    1. General information

    Data protection
    The protection of your privacy rights during the processing of personal data is important 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 point of contact
    The controller as defined by data protection law for the data processing relating to the receipt, assessment, and investigation of the tip-off is:

    TRATON SE
    Dachauer Str. 641
    80995 Munich, Germany

    which, in the context of the investigation process, acts in joint responsibility with the remaining Group companies of the Volkswagen Group according to Article 26 of the GDPR.


    To contact the Data Protection team or to exercise your data subject rights, please use the contact form.


    2. Collection and processing of personal data

    Purpose
    TRATON SE processes your data for the following purposes:
    Assessing and processing your tip-off and conducting necessary investigations against the affected person(s) associated therewith, and, where appropriate, for communication with authorities and courts in connection with your tip-off, communication with international attorneys and auditors or other investigating persons engaged by TRATON SE as well as other Group companies affiliated with TRATON SE.


    Obligation to provide your personal data
    You can submit a tip-off without sharing your personal data (anonymous tip-off). You are therefore under no obligation to provide your personal data.


    Type of personal data collected
    We collect the following personal data and information when you submit a tip-off:

    • your name and/or private contact and identification data, should you disclose your identity (non-anonymous tip-off)
    • your professional contact and (professional) organization data, if disclosed by you (non-anonymous tip-off), and, where applicable,
    • the names of persons and other personal data of the persons named in your tip-off.

    Legal basis
    The processing of your personal data is justified by the following legal basis:

    • Collection of your personal data in case of a non-anonymous tip-off: consent to the processing of personal data for the aforementioned purposes (implied consent) ( point (a) of Article 6(1) of the GDPR).
    • Collection, processing, and disclosure of personal data of the persons included in your tip-off: for the purposes of safeguarding the legitimate interests pursued by the controller or by a third party (point (f) of Article 6(1) of the GDPR ). It is a legitimate interest of TRATON SE to identify, process, rectify, and sanction violations of the law and severe breaches of duty of employees throughout the Group in an effective manner with a high level of confidentiality to avert damage and liability risks for the TRATON GROUP pursuant to sections 30, 130 of the Gesetz über Ordnungswidrigkeiten (OWiG — German Act on Regulatory Offenses). Point 4.1.3. of the German Corporate Governance Code requires the establishment of a whistleblower system to enable employees and third parties to disclose reports on legal violations within the company safely and in an adequate manner.
    • Disclosure of personal data in case of non-anonymous tip-off to other recipients: processing is necessary for compliance with a legal obligation (point (c) of Article 6(1) of the GDPR).

    3. Disclosure of personal data

    In certain cases, your personal data may be transmitted to other recipients: in substantiated individual cases, while processing a tip-off, or as part of an internal 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 Article 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 tip-off), 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.


    4. Data retention and erasure

    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, for as long as we are obliged to store it under national legal, contractual, or statutory retention periods.

    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.


    5. Your rights

    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, 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 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 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 event of data protection breaches, you have a data subject 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 details can be obtained via the link below:

    https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

    To revoke your consent (in case of a tip-off that is not anonymous) or to exercise your rights regarding your personal data, please use the contact information provided under “Controller and point of contact.”

    Information on the right to object to processing of your personal data at any time pursuant to Article 21(4) in conjunction with (1) of the GDPR

    You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you that is necessary to safeguard our legitimate interests or the legitimate interests of a third party. Please use the contact information provided under “Controller and point of contact” to raise an objection and state its grounds.

    We will assess whether we are obliged to erase your data due to your objection on the basis of the reasons you have provided. Please note that a further processing of your personal data might be necessary despite your objection. This is the case if compelling legitimate grounds override your interests, rights, and freedoms or if we have to establish, exercise, or defend legal claims. We will inform you about the result of our assessment.


    General questions about whistleblowing:

    If you have any general questions about whistleblowing, please contact the TRATON SE Investigation Office at investigation-office@traton.com or TRATON SE, Dachauer Straße 641, 80995 Munich, Germany.

  • Information on data protection according to Article 13 of the GDPR for Facebook fan page visitors/subscribers

    a) Controller


    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, Germany, registered in the commercial register of the Munich Local Court under the number HRB 246068. In the following, we inform you about the collection, processing, and use of your data.

    b) General information


    Below, TRATON SE informs you about the processing of your personal data within the framework of the fan page provided by TRATON SE. In its ruling of 5 June 2018, the European Court of Justice confirmed the joint responsibility of the fan page operator and Facebook. Information on data processing by Facebook Ireland Limited, 4 Grand Canal Square, Dublin2, Ireland (hereinafter referred to as “Facebook”) can be found in its Privacy Policy.

    c) Collection, processing, and use of your personal data


    The fan page you visit gives you the opportunity to react to our posts, 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 that may be accessible to us (e.g., Facebook user name, pictures, interests, contact details) will be used by us exclusively for the purpose of customer and prospective customer communication due to a predominant legitimate interest (point (f) of Article 6(1) of the 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.

    d) Tracking tools


    TRATON SE does not use the fan page to carry out any data processing other than the basic functions. Please note that Facebook Ireland Limited may use Tracking Tools as well as cookies, regardless of how TRATON SE uses the fan page. You can find more information on this in Facebook’s Privacy Policy.

    e) Your rights


    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 Article 17 of the GDPR are met. Thereafter you may, for example, request the erasure of your data insofar as it is no longer necessary for the purposes for which it was 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 Article 18 of the GDPR are met. This is the case, for example, if you dispute the accuracy of your data. You can then demand that the processing be restricted while the correctness of the data is being checked.

    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 legitimate interest of TRATON 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, commonly used, and machine-readable format and to transfer it to another data processor.

    Right of withdrawal: If the data processing is based on consent, you have the right to withdraw the data processing within the scope of said 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.

    f) Your contact


    To contact the Data Protection team or to exercise your data subject rights, please use the contact form.


  • Contacting Data Protection team and exercising data subject rights


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