This Data Privacy explains how personal data about you is collected, processed and used by ZF Friedrichshafen AG (hereinafter “ZF,” “we,” or “us”) as data controller when you use the ZF Aftermarket Websites available under aftermarket.zf.com.
At ZF, we take our responsibility to protect your personal data serious. As used in this Data Privacy “personal data” means any information – either alone or in combination with other information we can access – that relates to you as an identified or identifiable individual. We respect your right to privacy and will only process your personal data in accordance with applicable data protection laws. This Data Privacy applies to information we collect when you use the ZF Aftermarket Websites and its functionalities.
1. Information on Data Collection and Use
We collect certain information every time you visit our ZF Aftermarket Websites. This information is used for the purposes which we list below. The specific types of personal data we collect depend upon your activities on the ZF Aftermarket Websites, as also further explained below.
1.1. Information that is automatically collected
When you use the ZF Aftermarket Websites without registration, you are not required to actively provide certain personal data; however, we automatically collect and process the following information:
- technical session and connection information including IP address of your device; browser type; information about your device, hardware and software; preferences; web pages you visited just before the ZF Aftermarket Websites; pages you viewed on the ZF Aftermarket Websites and dates and times of your visit.
We process and use the data specified above for the purposes of (1) providing the ZF Aftermarket Websites and its functionalities; (2) improving the ZF Aftermarket Website’s features and functionalities; and (3) preventing and detecting misuse and malfunction of the ZF Aftermarket Websites including troubleshooting.
Collection of this type of information occurs inter alia by means of cookies. For more detailed information on the types of cookies and their specific purposes, please see Sec. 2 below.
The processing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the contract about the use of the ZF Aftermarket Websites; or (2) ZF has a legitimate interest in ensuring the functionality and error-free operation of the ZF Aftermarket Websites and that it is tailored to the user’s needs.
1.2. User requests, Account Creation and Signing-in
When you create a ZF Aftermarket Account (which is required for some parts of the ZF Aftermarket Websites), we collect the information you provide in the registration process, which may include:
- First name and surname, sex, email address, phone numbers, area of activity, industry category, name and type of your organisation, company’s address.
The same data is processed when the user fills in the contact form on the website, e.g. the user sends a request for technical information.
If you create or log in to a ZF Account we use your login data (user name and password) for the purpose of providing and administrating your access to the ZF Aftermarket Websites and – as the case maybe – further online services by ZF or third parties which are accessible through the ZF Aftermarket Websites. The information you provide in order to register (user name and password) is processed to check and verify your authorisation and to handle requests from you to reset your password.
In order to extend the period of validity of your login data, we additionally store the date and time of your last login on aftermarket.zf.com.
You are not obliged to provide personal data, unless a contrary contractual provision exists. However, without these data we cannot provide you with the corresponding functions of our website or process your enquiries.
1.3. Further services
You may provide further information to us when you order further services through the ZF Aftermarket Websites; such information may include: delivery address; payment information, etc. The collection and use of such additional information is governed by a separate Data Privacy for the particular service.
For more details regarding the usage of cookies visit Cookies.
3. Contact forms, Subscription to newsletters and other marketing communications
The ZF Aftermarket Websites may offer you the possibility to subscribe to a newsletter or other marketing communications which will be sent to you via email. For this purpose we process and use your name and email address in order to provide you with the newsletter and other subscribed communications. The type of newsletter depends on the selection company type and vehicle type in the registration form.
The processing and use of personal data for the purpose of subscriptions to newsletters and other marketing communications is based on (1) statutory provisions which justify those operations on the ground that the processing is necessary for the performance of the subscription; or (2) your consent.We only use your details to provide you with the newsletter and other subscribed communications.
We use the double-opt-in-procedure in order to verify your subscription / consent. We store your confirmation in order to document and prove your subscription / consent. You have the right to cancel your subscription / to withdraw your consent or to object to the processing of your personal data for this purpose at any time without incurring any costs other than the transmission costs in accordance with the basic tariffs. The cancellation / withdrawal of consent shall not affect the lawfulness of processing based on consent before the cancellation / withdrawal. If you do that, we’ll update our records immediately to reflect your wishes.
We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters.
We use a service provider as our data processor to deliver the newsletters who may only process the personal data in accordance with our instructions and who is bound by a data processing agreement.
For information about how long we hold your personal data, please see our General Data Protection Notice.
Our website uses Google reCAPTCHA to check and prevent automated servers ("bots") from accessing and interacting with our website. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).
Through certification according to the EU-US Privacy Shield https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.
This service allows Google to determine from which website your request has been sent and from which IP address the reCAPTCHA input box has been used. In addition to your IP address, Google may collect other information necessary to provide and guarantee this service.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the security of our website and in the prevention of unwanted, automated access in the form of spam or similar.
Google offers detailed information at https://policies.google.com/privacy concerning the general handling of your user data.
4. Order of brochures and further promotional materials
You can order brochures and – also in context of specific applications and services provided through the ZF Aftermarket Websites - further promotional and advertising materials on our ZF Aftermarket Websites. We process and use the information you provide (such as your name, address, further contact details as well as the selected brochure) to execute your order and send you the material in the desired manner (via email, postal service etc.).
The processing and use of personal data for these purposes is based on (1) statutory provisions which justify those operations on the ground that the processing is necessary for the performance of the orders; or (2) your consent. You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
5. Sharing data within the ZF Group
ZF is a company located in Germany which operates globally and is part of the ZF group of companies, the current members of which are specified here [www.zf.com/locations] (“ZF Group”). The data you provide to us in the course of registration for a ZF Account (see no. 1.2 above), will be stored in our centralised customer data base and shared within the ZF Group for the purpose of managing your relationship with ZF and the ZF Group.
The ZF Account information relating to you might be processed outside of your local jurisdiction and the European Economic Area including, in the following countries (www.zf.com/locations) e.g. US, Mexico, Canada, Ukraine, Turkey, Russia, China, Switzerland, Serbia, Japan, UAE, India, Australia, Singapore, Taiwan, Indonesia, Korea, Thailand, Malaysia, Vietnam, Philippines, South Africa, Algeria, Tunisia, Mauritius, Argentina, Brazil and Columbia.
Any transfer of your personal data to a third country (i. e. which is not a member of EU/EEA) will continue to be in compliance with all applicable data protection laws.
As far as a third country is not recognized by the European Commission to provide an adequate level of protection, ZF will take appropriate safeguards to ensure adequate protection of your data; e.g. by concluding data transfer agreements with third country recipients comprising standard contractual clauses which in accordance with the decisions of the European Commission provide adequate safeguards and can be requested under email@example.com.
Sharing data outside of the ZF Group
In order to provide certain Applications and Services we share your data with particular external parties which perform services on our behalf. We may use third party service providers to offer or facilitate services on our behalf, such as a newsletter service provider, IT-provider, web hosting provider as well as any other service provider which act as data processors and therefore process the data on our behalf and under our instructions. These third parties are prohibited from using your personal data for their own commercial, promotional or any other purposes than those explicitly instructed for and they have to follow our express instructions and comply with appropriate security measures to protect your personal data.
We might disclose personal information when required by law to comply with a current judicial proceeding, a court order or legal process served on us, or as otherwise required by any applicable law, rule or regulation.
6. Detecting and prosecute misuse
7. Deletion of Data
Generally, we delete personal data as soon as it is no longer necessary in relation to the purposes for which the data was initially collected or processed. In case the processing is based on consent and you withdraw your consent we will delete your personal data without undue delay after the withdrawal unless we are legally required to retain the data.
With respect to registered users, ZF will annually send a reminder to re-confirm the information he provided to ZF when registering for the ZF Account. Should the user not confirm his Account information, the Account will be deactivated. ZF will delete the ZF Account and related data after another year after the deactivation in case the user does not provide the relevant confirmation.
8. Other services, applications and websites
Via the ZF Aftermarket Websites you may access other services and applications the use of personal data by which is explained in separate date protection information documents. Also, our ZF Aftermarket Websites contains links to other websites. ZF is not responsible for the use and protection of personal data on these other sites. We encourage you to be aware when you leave our ZF Aftermarket Websites and to read the data protection information of the other websites.
9. Your rights
You are generally entitled to request from ZF access to and rectification or erasure of personal data that we store about you or – as the case maybe - restriction of processing as far as it concerns you or to object to processing as well as the assert your right to data portability; all as granted by applicable data protection laws. You also have the right to lodge a complaint with a supervisory authority.
As far as you are entitled to further or modified rights beyond the rights set forth herein under applicable national law, these remain unaffected by the rights and claims set forth in this Data Protection Information. This also includes any claims for damages on the basis of a violation by ZF of the applicable data protection law as well as the right to provide us with guidance on the management of your data in the event of your death.
In case of any request concerning our use of your personal data or in case you want to assert any of your rights mentioned under Sec. 10, you may contact us by email firstname.lastname@example.org or by using our contact form which is accessible here: aftermarket.zf.com/contact.
The contact details of our data protection officer are as follows:
ZF Friedrichshafen AG
Löwentaler Straße 20
11. Changes to this Data Protection Information
As our collection and processing of your data may change over time, we might also modify this Data Privacy in order for it to always correctly reflect our data processing practices. We encourage you to review it from time to time.
Last modified 02/2021