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Privacy Notice

Third Party Privacy Notice

Dura-Line is committed to ensuring that your privacy is protected and we comply with the General Data Protection Regulation 2016/679 (”GDPR”) and other relevant data protection laws applicable  in each country in which we operate, together with marketing, cookies laws and associated guidance (together the "Data Protection Laws").

This privacy notice applies to your interaction with all internet sites and mobile applications operated by or on behalf of Dura-Line and its Group entities worldwide. It also applies to the processing of personal data by Dura-Line and each member of its Group which we may otherwise collect about you, including when you:

  • use any of our websites;
  • use any of our apps;
  • use of any of our IT systems, including messaging and collaboration platforms ("IT systems");
  • contact us or when we contact you;
  • apply for one of our vacancies;
  • purchase goods or services from us;
  • provide services or goods to us (where, for example, you are a sole trader, partnership or where you are providing services or goods on behalf of your employer/contractor);
  • visit our sites; and
  • which we may otherwise collect and process about you

A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. The controller for personal data collected under this privacy notice is Dura-Line Corporation Inc and/or the relevant Dura-Line Group entity that you are dealing with, or with whom your data may be shared as explained further in this notice.

This notice explains how we use, store and share the information we collect about you, how you can exercise your rights in respect of that information and the procedures that we have in place to safeguard your privacy. This notice supplements any other fair processing or privacy notice that may be provided to you from time to time. Please contact our Data Protection Officer, Andreas Reinke, by email at reinke@datenschutzbeauftragter.ruhr if you have any questions, comments or concerns about this notice or how we handle your personal information, or if such information changes at any time.

Who is this notice addressed to?

References in this notice to “you” or “your” are references to individuals whose personal data Dura-Line and the members of its Group collects and processes.

If you have provided your personal data to Dura-Line for recruitment activities (whether directly or through a third party) this notice is only designed to provide you with information about how we will process your personal data during the application and recruitment processes.

References in this notice to “Dura-Line”, “we”, “us” or “our” are references to Dura-Line Corporation, and each other Group entity. For the avoidance of doubt, our Group entities are:

Group entity:

Registered address:

Dura-Line Corporation, Inc

11400 Parkside Drive, Knoxville, Tennessee 37934, United States

Dura-Line Germany GmbH

Lilienthalstrasse 30, 49716 Meppen, Germany

Dura-Line CT s.r.o.

U Pisåku 682, 763 62 Tlumacov, Czech Republic

Dura-Line France SA

ZI de Motz-Serrieres, 73310 Motz, France

Dura-Line Norway AS

Karihaugveien 89, 1086 Oslo, Norway

Dura-Line Sweden AB

Kjulamon 6, 635 06 Eskilstuna, Sweden

Dura-Line Poland Sp.z.o.o.

Kościńskiego 23, 96-502 Sochaczew, Poland

Dura-Line Middle East LLC

P.O Box: 3017, P.C 112 Ruwi, Muttrah, Oman

Dura-Line India Private Limited

Sanskrit Bhawan, Aruna Asaf Qutab Institutional Area, New Delhi , IN, 110 067, India

This notice applies to information relating to individuals (i.e. natural persons), sole traders and partnerships but not to information relating to corporations. It applies to representatives of corporations if those representatives are individual persons. This is because Data Protection Laws only apply to information relating to natural persons. Information relating to corporate bodies may still be protected by other laws such as confidentiality and we take those obligations seriously as well.

Please note: this notice does not cover third party websites that we may link to from our Website or the processing of personal data by third parties with whom we may share your data which shall in each case be governed by each third party's own privacy notices, unless specifically mentioned in this notice.

We are not responsible for the privacy policies and practices (including use of cookies) of such third parties even if you accessed the third party website using links from our Website. We recommend that you check the notice of each website you visit and contact the owner or operator of such website if you have concerns or questions.

The information we collect and how we use it  

Under the Data Protection Laws, we are required to explain what information we collect from you and how and why we use your personal information (the "processing activity"). We are also required to have a "lawful basis" on which to process your personal information. This is summarised in the table below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may also anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes.  Such information will not identify you individually.

Processing activity: Why we use your information?

What information is collected?

Lawful basis of processing

Where is the information collected from?

How long do we keep the information for?

To enter into and administer our contracts with customers and suppliers, including setting up customer accounts, administering services we perform or receive, and collecting payments due to us.

 

Customers, Suppliers and their respective Representatives:

·  name;

·  address (incl. postcode);

·  phone number;

·  email address;

·  username;

·  password; and

·  account number.

 Customers and Suppliers only:

·  contract information;

·  payment method details;

·  payments made or due, including invoice details;

·  details of authorised person(s) on the account; and

·  identity document (e.g. driver's licence or passport).

Customer and Supplier Representatives only:

·  your authorisation by the Customer/ Supplier; and

·  your role within the Customer's/ Supplier’s business.

If you are a Customer or Supplier, we process this information as it is necessary for us to enter a contract with you and to perform that contract.

If you are a Customer or Supplier Representative, we process this information as it is necessary for our legitimate interest to provide and receive goods and services.

Directly from you via our Website or when you call or email us.

 

For the duration you hold an account with us and for 6 years following the closure of your account.

To promote our products and services, including by sending you newsletters and marketing emails.

·  name;

·  e-mail address;

·  additional information such as your job role; and

·  what market you work in.

The processing is necessary for our legitimate interest to promote our business and our products and services.

We will only send you marketing by email to a personally owned email address if you have given us your prior consent, which you are free to refuse.

You have a right to stop us from sending you direct marketing at any time. You may do so by clicking the "unsubscribe" link in our marketing emails, or by contacting our Data Protection Officer using the details set out in this notice.

Directly from you via our Website or when you call or email us, or where otherwise provided to us by you as part of a trade show or otherwise.

2 years from the date of our last contact with you

To answer questions or comments via contact forms.

·  name;

·  email address;

·  (optional) address;

·  telephone number; and

·  company name.

The processing is necessary for our legitimate interest to provide our services to you and/or provide Website visitors with a good level of service.

Directly from you via our Website or when you call or email us.

3 months from the date on which we resolve the enquiry

To analyse use of our Website in order to improve our products and services.

·  an identifier that corresponds to your device;

·  IP address;

·  information about the device you use e.g. operating system, model, language settings;

·  duration, frequency and time of use;

·  click through information – the way you browse through and use our Website; and

·  region.

We only collect and process usage data for this purpose if you give us consent.

You may withdraw consent through the Website's cookie consent manager.

 

From you via our Website.

The data will be aggregated after a maximum period of 1 year from when it is collected.

To motivate and stay connected to our customers and potential customers via online campaigns.

·  newsletter subscription information;

·  addresses;

·  phone numbers; and

·  product usage.

The processing is necessary for our legitimate interest to promote our business and our products and services.

We will only send you marketing by email to a personally owned email address if you have given us your prior consent, which you are free to refuse.

You have a right to stop us from sending you direct marketing at any time. You may do so by clicking the "unsubscribe" link in our marketing emails, or by contacting our Data Protection Officer using the details set out in this notice.

Directly from you via our Website or when you call or email us.

2 years from the date of our last contact with you

To comply with legal and regulatory obligations., including:

Screening for financial and other sanctions or embargoes.
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator

 

·  contact information provided by you.;

·  other information provided by you;

·  CCTV images

The processing is necessary for us to comply with our legal obligations.

Directly from you via our Website or when you call or email us.

Information may also be provided by credit reference agencies, data brokers or aggregators, government bodies and other third party sources.

For the duration you hold an account with us and for 6 years following the closure of your account.

For call recording and monitoring purposes

·  contact information provided by you;

 

When you contact us by telephone your call may be recording for training and monitoring purposes.  The processing is necessary for our legitimate business interests to protect our staff and customers and to perform a contract with you (where such call recording shall be used to verify any request or statement made as part of any order or otherwise deal with customer management).

Directly from you when you call us.

 

6 months from the date of the call

To prevent and detect unlawful activities such as fraud and money laundering.

Customers, Suppliers and their respective Representatives:

·  name;

·  account number;

·  company involvements – e.g. director, beneficial owner;

·  information relating to your use of our services; and

·  reports provided by fraud prevention agencies.

Customers and Suppliers only:

·  information about credits and debtors processed through the services;

·  payment transaction reference; and

·  transaction data including transaction history.

The processing is necessary for our legitimate interests to protect our business and co-operate with law enforcement authorities.

Directly from you via our Website or when you call or email us.

We hold this information for 6 years after the relevant issue arises or, if litigation is pursued, until the issue is finally resolved.

To process job applications of prospective employees of Dura-Line that set up a career opportunities account.

·  name;

·  email address (incl. postcode);

·  CV information;

·  country/region of residence.

·  references;

·  correspondence with you relating to any application;

The processing is necessary for our legitimate interest to review and interview job candidates.

Directly from you via our Website or when you call or email us.

6 months following an unsuccessful application

To reply to and deal with complaints and queries.

Customers and Customer Representatives:

·  name;

·  title;

·  address (incl. postcode);

·  phone number;

·  email address; and

·  account number.

 

The processing is necessary for our legitimate interest to provide customers with a good service.

Directly from you via our Website or when you call or email us.

If the data relates to a complaint, we will retain it for 6 years from when the issue is finally resolved.

Otherwise, we will hold this data for 3 months.

Where we process personal data on the legal basis of 'legitimate interests' (as indicated in the above table), we have determined, acting reasonably and considering the circumstances, that we are able to do so after carrying out a balancing exercise to make sure that our legitimate interests are not overridden by your interests, rights and freedoms. Where we rely on this legal basis, (a) we process the data only to the extent that is necessary for the relevant purpose; and (b) the relevant processing activities can be reasonably expected. The legitimate interests we pursue are specified in the above table with respect to each relevant purpose.

Where we process personal data on the legal basis of 'consent' (as indicated in the above table), you may refuse to consent to our processing and you may also withdraw your consent at any time: (i) in respect of cookies and other tracking mechanisms used on our Website, by using the cookie consent manager in our cookie notification banner, (ii) in respect of marketing communications, by clicking ‘unsubcribe’ in the footer of the relevant emails, or (iii) in respect of other matters, by contacting our Data Protection Officer on the details provided above. This would not affect your ability to use any features of our Website. Withdrawing consent does not affect any processing carried out without your consent.

Marketing and promotional materials

We may use your personal information to provide you with marketing and promotional materials (as stated above). We do so for our own purposes and will never sell or share your personal information with third parties for marketing purposes.

We will share such marketing and promotional materials only if your explicit consent has been obtained beforehand. Should you provide your consent but later change your mind you may opt-out of receiving marketing and promotional materials from us at any time by using the 'unsubscribe' link in the marketing or promotional email or by contacting our Data Protection Officer on the details provided above.

Security

We have in place appropriate policies, rules and technical and organisational measures to protect your personal information from unauthorised or unlawful processing, and against accidental loss, destruction or damage.

We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

However the Internet and email are not secure. Your communications may route through a number of countries before being delivered, may be intercepted by third parties and may not always reach the intended recipient – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any such unauthorised access or loss of personal information that is beyond our control.

You are responsible for protecting your username and password and must not share it with, or disclose it, to anyone.

Sharing your personal information

We will only disclose your personal information to:

  • companies within our group both in and outside of the UK/European Economic Area;
  • our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);
  • other third party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes;
  • analytics or search engines, that enable us to optimise and improve your Website experience;
  • other third party suppliers for marketing purposes;
  • third parties that you approve (including without limitation, social media sites and third party payment providers);
  • our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters; and
  • tax authorities or agencies to comply with our legal and regulatory obligations.

We will disclose your personal information to third parties:

  • in the event that we consider selling or buying any business or assets, in which case we will disclose your personal information to any prospective sellers or buyers of such business or assets;
  • in the event we are the subject of any insolvency situation (e.g. the administration or liquidation);
  • if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
  • where you have provided your consent;
  • in order to enforce or apply our terms and conditions;
  • to protect our rights, property, or safety, or that of our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation tax authorities, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

International transfers of your personal information

We may transfer personal information to countries other than the country in which the data was originally collected (for example, outside the UK or the European Economic Area (“EEA”)) in order to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.

We have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice. For example, if we transfer personal data from the UK/EEA to one of our group companies or a processor located in a country outside the UK/EEA, such as the United States, we will implement an appropriate data export solution such as the European Commission's Standard Contractual Clauses or otherwise take measures to provide an adequate level of data protection in accordance with Data Protection Laws.

A copy of the standard contractual clauses are available on the European Commission's website here.

Your rights

Right

Description

To be informed

You have the right to be informed about the personal information we hold about you.

Of access

You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.

To rectification

You have the right to request that we rectify your personal data if it is not accurate or not complete.

To erasure

 

You have the right to ask us to delete the personal information we hold about you. This right will only apply where (for example):

·       we no longer need to use the personal information to achieve the purpose we collected it for;

·       where you withdraw your consent if we are using your personal information based on your consent; or

·       where you object to the way we process your data (in line with Right 7 below).

To restrict processing

 

In certain circumstances, you have the right to restrict our processing of the personal information we hold about you. This right will only apply where (for example):

·       you dispute the accuracy of the personal information held by us;

·       where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead; or

·       where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims. 

To data portability

 

In certain circumstances, you have the right to receive the personal information you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.

To object

 

You have the right to object to our processing of the personal information we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims.

In relation to automated decision making and profiling

You have the right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing or profiling.

To withdraw

You have the right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).

To post-mortem guidance

Applicable to French data subjects: you have the right to provide guidelines regarding the retention, deletion and communication of your personal data after your death.

To complain

If you deem that your rights under the applicable local laws and regulations have been infringed, you have the right to lodge a complaint with the competent supervisory authority for data protection in your country.

We welcome your views about our Website and this notice. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please contact our Data Protection Officer using the details provided above.  

If you would like this notice in another format (for example audio, large print, braille) please contact us using the details above.

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal information. However, as noted above, you also have the right to make a complaint to your local supervisory authority. Contact information relating to these authorities is below:

UK

First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

Germany

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, Husarenstraße 30, 53117 Bonn

France

Commission Nationale de l'Informatique et des Libertés – CNIL, 8 rue Vivienne, CS 30223, F-75002 Paris, Cedex 02

Czech Republic

The Office for Personal Data Protection, Urad pro ochranu osobnich udaju, Pplk. Sochora 27, 170 00 Prague 7.

Poland

The Bureau of the Inspector General for the Protection of Personal Data – GIODO, ul. Stawki 2, 00-193 Warsaw.

Norway

Datatilsynet, P.O. Box 458 Sentrum, NO-0105 Oslo

Sweden

Datainspektionen, Drottninggatan 29, 5th Floor, Box 8114, 104 20 Stockholm

 

Cookies

A cookie is a small text file that is stored on your computer or other device when you visit a website. They are very widely used in order to make websites function properly, or more efficiently, as well as provide information to the owners of the site.

Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages people find useful and which not. A cookie in no way gives us access to your computer or any personal information about you, other than the data you choose to share with us. We use cookies to collect information about your usage of our website. This helps us to give you the best possible user experience.

We only use cookies if you give your consent for us to do so, with the exception of cookies which are essential for the website to function. You can update your cookie consent by following [this link] to our cookie notification banner where your preferences can be amended. Not consenting to the use of cookies may prevent you from taking full advantage of the website.

For further information about the types of cookies we use, why, and how you can control cookies, please see our Cookie Notice here.

Changes to this notice

We will take reasonable measures to communicate any changes to this policy to you and will post any updated privacy policies on this page.

This notice was last reviewed and updated in April 2021.