Page last updated: May 2, 2023
1. Introduction
Yokohama TWS is responsible for how we handle
your personal data. Yokohama TWS comprises Trelleborg Wheel Systems Holding AB
(a joint stock company incorporated in Sweden, registration number 556212-8255)
and its direct and indirect subsidiary undertakings (referred to collectively
as "Yokohama TWS" or "we" or "our"). For the
purposes of Applicable Data Privacy Laws (as defined below), your data will be
controlled by the Yokohama TWS affiliate or subsidiary undertaking that you
have instructed or that is providing products or services to you or
communicating to you or which has otherwise initially collected your data and
decided the purposes and means for using your data and each such entity is
regarded as an independent data controller of your personal data. This notice
applies to all such entities.
This privacy notice ("Privacy
Notice") sets out which Personal Data that we collect on our websites by
e-mail and/or by entering into and fulfilling an agreement with the company you
represent, and for which purposes the Personal Data are processed. Throughout
this Privacy Notice the term "processing" is used to cover all activities
involving your Personal Data, including collecting, handling, storing, sharing,
accessing, using, transferring, and disposing of information.
"Applicable Data Privacy Laws" means
all legislation and regulations, including regulations issued by relevant
supervisory authorities, protecting the fundamental rights and freedoms of
individuals and, in particular, their right to privacy with respect to the
processing of Personal Data that from time to time apply to Yokohama TWS,
including without limitation data protection laws and regulations implementing
the Data Protection Directive 95/46/EC and as of 25 May 2018 the Regulation
(EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on
the protection of natural persons with regard to the processing of personal
data and on the free movement of such data, and repealing Directive 95/46/EC
(General Data Protection Regulation) (the "GDPR").
"Personal Data" is defined as any
information relating to an identified or identifiable natural person.
2. Cookies – why do we collect and process
your Personal Data
Yokohama TWS uses cookies and other similar
techniques to collect information about you and your device (such as phone or
computer) when you visit our website. For more information regarding Yokohama
TWS's use of cookies and a description of the current purposes your Personal
Data may be used for, please view our cookie policy. The purposes for
which we use cookies include:
2.1. Personalize our interactions with you -
offering relevant products and services
When you visit our websites, landing pages and
submit forms on those websites we may collect and process your Personal Data in
order to better understand you as a customer and to personalize our
interactions with you, for example to show you products and services we think
you may like.
We look at your use of the website, for
example where you have clicked, your visit frequency, time spent per visit etc.
Personal Data processed for these purposes
include:
IP-address
Device id
Country or region
Post / zip code
E-mail address
First name
Last name
Company/organization name
Job role
Phone number
Business sectors
Areas of interest
Document downloads, Video views, contact form
submissions, page views, visit frequency etc.
Original source ("referral") before
visiting our websites, such as which e-mail link, website, social media post,
advertisement clicks, etc. that led your visit to our website.
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to better understand you as a customer and to personalize
our interactions with you to show you relevant products and services, article
6.1 f) GDPR.
2.2. Identify potential customers and business
opportunities
When you visit our websites, landing pages and
submit forms on those websites we may collect and process your Personal Data in
order to identify if you could be a potential customer or business opportunity.
We look at your use of the website, for example where you have clicked, your
visit frequency, time spent per visit etc.
Personal Data processed for these purposes
include:
IP-address
Device id
Country or region
Post / zip code
E-mail address
First name
Last name
Company/organization name
Job role
Phone number
Business sectors
Areas of interest
Document downloads, Video views, contact form
submissions, page views, visit frequency etc.
Original source ("referral") before
visiting our websites, such as which e-mail link, website, social media post,
advertisement clicks, etc. that led your visit to our website.
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to identify potential customers and business opportunities,
article 6.1 f) GDPR.
2.3. Identify usage trends and compile
statistics
When you visit our websites, landing pages and
submit forms on those websites we may collect and process anonymized Personal
Data in order to identify usage trends and for statistical purposes. We look at
from which geographic regions our users are, such as country and language
settings.
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to identify usage trends and to compile statistics, article
6.1 f) GDPR.
3. Why do we collect and process your Personal
Data
3.1. Provide you with information such as
Newsletters, Catalogues, Press Releases, Chatbots and Webinars
If you sign up to subscribe to newsletters,
catalogues, press releases, chatbots, webinars and similar information about
Yokohama TWS and its business or order such information on a one-time basis we
process your Personal Data for the purposes of providing you with the requested
subscription or information. We will check the e-mail address you have entered
to ensure that you are indeed the owner of the e-mail address provided or that
its owner is authorized to receive the newsletter. For this purpose, we will
send you an e-mail to the e-mail address you provided, which you will then
confirm receipt of. After confirming the e-mail, you are registered for our
newsletter.
Personal Data processed for these purposes
include:
Salutation
First name
Last name
Address
Post / zip code
City
Country
E-mail address
Business e-mail
Phone number
Company/organization/Industry
Job title
Areas of interest
Password
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to provide you with the subscription and information you
have requested, article 6.1 f) GDPR. If you do not provide information marked
with * on the website form, we will not be in a position to provide you with
the requested service.
3.2. Answer your Questions and handle Feedback
in general
Most of our websites, as well as our corporate
pages in social media (such as Facebook), provide functionality for the visitor
to communicate with us to ask questions and give feedback regarding our
services and business. Where you use such functionality, Yokohama TWS processes
your Personal Data for the purposes of answering your questions and handle
feedback from you. This may also include deletion of comments made on social
media corporate pages and reporting to the social media network provider of
un-appropriate comments. In addition, the data collected in this way will be compared
with data that may be collected elsewhere by us if you have previously given us
the corresponding consent, which you can withdraw at any time with effect for
the future. To exercise the withdrawal, please contact the office mentioned at
the end of this statement.
Personal Data processed for these purposes
include (to the extent you choose to submit such information):
First name
Last name
E-mail address
Address
Phone number
Feedback and comments made by you
Website source
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to answer questions and handle feedback from you, article
6.1 f) GDPR. If you do not provide information marked with * on the website
form, we will not be in a position to provide you with the requested service.
3.3. Handle communications and orders or
complaints sent by you through e-mail, fax and similar
If you send an e-mail or facsimile to one of
our employees, we will process your Personal Data provided to handle your
request or order.
Personal Data processed for these purposes
include:
First name
Last name
E-mail address
Address
Phone number
Other Personal Data provided by you
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to answer requests and handle orders or complaints from
you, article 6.1 f) GDPR.
3.4. Create personal Website User Accounts
Some of Yokohama TWS's websites allow users to
set up a personal user account with log-in. For those websites and if you
create a user account Yokohama TWS will process your Personal Data for the
purposes of creating and managing your personal user account, create your
log-in, provide you with access to your account and manage your subscriptions
and/or requests.
Personal Data processed for these purposes
include:
First name
Last name
E-mail address
Customer number
Phone number
Your subscriptions and/or requests
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest to create and manage your user account and fulfil the user
account agreement with you, articles 6.1 b) and f) GDPR. If you do not provide
information marked with * on the website form, we will not be in a position to
provide you with the requested service.
3.5. Manage complaints relating to our
services and products
Some of our websites allow you to provide us
with complaints relating to our services and products. Where you provide us
with a complaint, Yokohama TWS will process your Personal Data for the purposes
of investigating, managing, and replying to your complaint.
Personal Data processed for these purposes
include:
First name
Last name
E-mail address
Phone number
Customer reference number
Company/organization
Complaints and comments by you
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to fulfil our
legitimate interest of investigating, managing, and replying to your complaint,
article 6.1 f) GDPR. If you do not provide information marked with * on the
website form, we will not be in a position to provide you with the requested
service.
3.6. Manage your request for a quotation or
order relating to our products and services
Some of our websites allow you to request a
quotation or order products and services provided by Yokohama TWS. Where you
provide us with a request for a quotation or an order, Yokohama TWS will
process your Personal Data for the purposes of managing the request or order.
Personal Data processed for these purposes
include:
First name
Last name
E-mail address
Address
Phone number
Company/organization
Organization number
Invoice address
Customer number
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to perform a
contract between you and Yokohama TWS or in order to take steps prior to
entering into a contract, article 6.1 b) GDPR. If you do not provide
information marked with * on the website form, we will not be in a position to
provide you with the requested service.
3.7. Manage your request regarding data
privacy
Should you contact us to request one of the
following data privacy actions (i) to be provided with a register extract, (ii)
to restrict processing, (iii) to update, delete or transfer personal data, (iv)
to object to personal data processing or to automated decision making, to (v)
file a data privacy complaint, or to (vi) opt out of marketing communication,
Yokohama TWS will process your Personal Data for the purposes of managing the
request.
Personal Data processed for these purposes
include:
First name
Last name
E-mail address
Country
Request details
Other information as necessary for the purpose
of handling and responding to your request.
The legal basis for the above processing of
your Personal Data is that the processing is necessary for Yokohama TWS’s
compliance with legal obligations, article 6.1. c) GDPR.
3.8. Enter into and fulfil an agreement with
the company you represent
Should the company you represent choose to
enter into an agreement with Yokohama TWS, we will process your Personal Data
for the purposes of entering into and fulfilling the agreement.
Personal Data processed for these purposes
include:
First name
Last name
Orders, information, requests, notifications,
and complaints etc. by you
We would also process other data, not
constituting your Personal Data, such as company e-mail address, company
address, company phone number, company/organization, organization number,
company invoice address, company customer number.
The legal basis for the above processing of
your Personal Data is that the processing is necessary in order to perform a
contract between you and Yokohama TWS or in order to take steps prior to
entering into a contract, article 6.1 b) GDPR.
4. For how long do we keep your Personal Data
Yokohama TWS will retain Personal Data for the
period necessary to fulfil the purposes outlined in this Privacy Notice unless
a longer retention period is required or permitted by local law to which
Yokohama TWS is subject. We are using the following criteria to establish our
retention period: (i) as long as we have an ongoing relationship with you
(either as an individual or in your capacity as employed by one of our
corporate customers, suppliers or co-operations partners or media, or as an
investor/owner, board member or analyst); (ii) as required by legal obligations
to which Yokohama TWS is subject (such as tax and accounting obligations); and
(iii) as advisable in light of our legal position (such as applicable statutes
of limitations).
5. Disclosure and transfer of Personal Data
Group companies
Yokohama TWS may disclose Personal Data
processed to other companies within the Yokohama TWS group. Yokohama TWS has
made sure to apply appropriate safeguards to your Personal Data in case of any
such transfer of your Personal Data within the Yokohama TWS Group by entering
into an Intra-Group Data Transfer Agreement, implementing the European
Commission Standard Contractual Clauses to any such transfer.
Other recipients
Courts and outside counsels: Purpose of
transfer: In order to exercise, establish or defend legal claims. Legal basis:
To fulfil our and your legitimate interest to have disputes settled by
competent courts.
To any successor in connection with a sale,
merger, divestment, or reorganization: we may disclose Personal Data as part of
an asset to a new owner on the basis of our legitimate interest under the
condition that the successor will process the data for the same purpose as
Yokohama TWS.
Data processors acting on behalf of Yokohama
TWS
Moreover, Yokohama TWS may disclose Personal
Data to external parties, such as vendors and service providers processing
Personal Data under the instructions of Yokohama TWS. Where such disclosure
entails transfers of Personal Data outside the EU/EEA, Yokohama TWS will ensure
that European Commission Standard Contractual Clauses have been entered into
between the transferring Yokohama TWS entity and the receiving external party.
Alternatively, other safeguards will be put in place prior to such transfers.
6. Security
6.1. We will ensure that the access to your
Personal Data is accurately secured by applying appropriate safeguards,
depending on the circumstances taking into account the state of the art, the
costs of implementation and the nature, scope, context and purposes of
processing as well as the risk. In support of this commitment, we have
implemented appropriate technical, physical, and organizational measures to
protect your Personal Data against unauthorized or accidental destruction,
alteration, or disclosure; misuse; damage; theft or accidental loss; or
unauthorized access.
7. Your rights
7.1. Right of rectification
Yokohama TWS will take steps in accordance
with Applicable Data Privacy Laws to keep your Personal Data accurate,
complete, and up to date. If you identify that any Personal Data related to you
is inadequate, incomplete, or incorrect, you are entitled to have the Personal
Data corrected.
Moreover, you also have the right to request
access to the Personal Data that we process about you.
7.2. Further rights as of 25th May 2018
As of 25th May 2018, you may under Applicable
Data Privacy Laws also in addition to rectification be entitled to:
(i) Access
You may request confirmation whether or not
Personal Data is processed and if that is the case access to your Personal Data
and additional information such as the purposes of the processing. You are also
entitled to receive a copy of the Personal Data undergoing processing. If the
request is made by electronic means the information will be provided in a
commonly used electronic format if you do not request otherwise.
(ii) Object to certain processing
You may object to processing of your Personal
Data processed on the basis of a legitimate interest, on grounds relating to
your particular situation and to processing for direct marketing purposes. If
you have opted to receive a subscription by e-mail each e-mail will include an
easily accessible opt-out function where you may de-register from further
communication.
(iii) Erasure
You may have your Personal Data erased under
certain circumstances such as when your Personal Data is no longer needed for
the purposes for which it was collected.
(iv) Restriction of processing
You may ask us to restrict the processing of
your Personal Data to only comprise storage of your Personal Data under certain
circumstances such as for example when the processing is unlawful, but you do
not want your Personal Data erased.
(v) Withdrawal of consent
You have the right to at any time withdraw
your consent to processing of Personal Data to the extent the processing is
based on your consent.
(vi) Data Portability
You may ask to receive a machine-readable copy
of the Personal Data processed on the basis of your consent or on the basis
that the processing is necessary in order to perform an agreement with you, and
which Personal Data has been provided to Yokohama TWS by you (data portability)
and ask for the information to be transferred to another data controller (where
possible).
7.3. Complaints to the supervisory authority
You acknowledge that you always have the right
to lodge complaints pertaining to the processing of your Personal Data to the
competent data protection authority if so provided under Applicable Data
Privacy Laws. A list of supervisory authorities in the European Union,
including our lead supervisory authority in Italy, the Italian Authority for
Privacy Protection (ITA - Garante per la protezione dei dati personali), can be
accessed here.
8. Contact information
If you have any questions or concerns
regarding the processing of your Personal Data or wish to exercise any of your
rights or obtain a copy of the safeguard mechanisms put in place to protect
your Personal Data in case of any transfer, please contact us by using
this using this contact form.
For further information on how you can contact
Yokohama TWS, please see below.
YOKOHAMA TWS
Head Office at:
Trelleborg Wheel Systems Italia S.p.A.
Via Naz. Tiburtina, 143
IT-00010 Villa Adriana (Roma)
Italy
Tel: +39 0774 38 41
9. Country specific addenda
