Privacy Statements

Nokian Tyres plc (“Nokian Tyres” or “we”) is the controller for the personal data concerning our corporate business contacts, namely the representatives or contact persons of corporate customers. Nokian Tyres is also the controller for the personal data concerning consumers who have registered for our services or might have subscribed for various publications (i.e. Nokian Tyres newsletter). 

This Privacy Statement describes how Nokian Tyres in the context of its business process the personal data of consumers and corporate business contacts (“customer”). Protection of customer’s privacy is important to us. Nokian Tyres is committed to processing personal data transparently and in compliance with applicable data protection laws. 

CONTROLLER AND CONTACT INFORMATION 

Nokian Tyres plc is the controller of our customers’ personal data. Any questions regarding our customers’ privacy can be directed to us: 

Nokian Tyres plc 
Privacy 
Pirkkalaistie 7 
37100, Nokia, FINLAND 
[email protected] 

PURPOSES OF PROCESSING, CATEGORIES OF PERSONAL DATA & LEGAL BASIS 

CUSTOMER – CORPORATE BUSINESS CONTACT 

Personal data is primarily obtained in situations where a corporate customer has acquired products or services from Nokian Tyres or when a corporate business contact has registered into our digital services. Personal data is processed for the following purposes:  

• To deliver products and services for our corporate customers.   

Personal data processed for this purpose includes contact information, billing information and other information that customer or employee of a customer has provided us during the provision of our products. 

• To maintain business relationship with our corporate customers in context of customer service and communication, managing customer meetings and leads.  

Personal data processed for this purpose includes information related to customer service such as contact information, information submitted via surveys and feedback forms, information about participation to events and campaigns, newsletter subscriptions or other data provided to us in the context of customer service requests. Phone calls to customer service are recorded in order to ensure the quality of customer service.  

• To develop our products and services in context of customer surveys and reviews, and website analytics.  

Personal data processed for this purpose includes contact information, terminal equipment identifiers, online identifiers, data related to our customers online activity and preferences, and data that might be inferred. Usually, the personal data will be aggregated, or other ways anonymised for compiling statistics and reports for business and product development. More information about our practice regarding cookies is available here.  

• To sell and market our products and services such as online and postal advertisement. 

Personal data processed for this purpose includes contact information, behavioural information, terminal equipment identifiers, online identifiers and purchase information. Collected personal data is further processed in order to create target audiences and offer targeted content. Targeted content is always based on segments or audiences and not on our customers individual behaviour.  

• To provide Nokian Tyres Dealer Services for our corporate customers. 

Personal data processed for this purpose includes contact information, terminal equipment identifiers, online identifiers and information related to identity management such as authorization information.  

• To organize and manage customer events such as trade fairs and Nokian Tyres product launches.  

Personal data processed for this purpose includes contact information and travel and accommodation information.  

• Fulfilling statutory obligations and any other official rules and regulations 

Personal data processed for this purpose includes any information relevant regarding a statutory requirement.  

Legal basis for processing our corporate customer’s personal data is always one of the following:  

• Consent 

With regards to newsletter subscription, we process personal data only if a customer has given consent for it. Customers can withdraw their consent for direct electronic marketing purposes by using “unsubscribe link” at the end of the received email message.  

• Contract 

We process our corporate customer’s personal data on a contractual basis when providing our Marketing Toolbox -service.  

• Legal Obligation 

In relation to fulfilling our statutory obligations the legal basis of processing is our legal obligation.  

• Legitimate interest 

We process personal data based on our legitimate interest in the context of developing, selling, marketing, delivering and providing our products and services, to maintain business relationship with our customers, and to organize and manage customer events. 

To ensure that a significant and pertinent relationship exists between Nokian Tyres and a customer, and to demonstrate that our legitimate interest does not cause any significant intrusion of our customers’ privacy, or any other undue impact on interests and rights, we assess the processing with balancing tests. More information on the balancing test can be requested by contacting [email protected]. 

PURPOSES OF PROCESSING, TYPES OF PERSONAL DATA & LEGAL BASIS 

CONSUMER CUSTOMER 

Personal data is primarily obtained during the sign-up for our services, when ordering our publications such as newsletters, or in connection with our surveys and competitions. In addition, personal data may also be obtained and derived from service use or when you submit a guarantee claim or return. We process personal data for the following purposes:  

• To deliver newsletter and other publications to recipients who have subscribed to receiving these. 

Personal data processed for this purpose includes contact information such as contact information, terminal equipment identifiers and behavioural information.   

• To provide customer service for our consumer customers 

Personal data processed for this purpose includes information related to customer service such as contact information, information submitted via feedback forms or other data provided to us in the context of customer service requests. Phone calls to customer service are recorded in order to ensure the quality of customer service.  

• To market and advertise our products and services such as online and postal advertisement.   

Personal data processed for this purpose includes contact information, terminal equipment identifiers, online identifiers, behavioural data, data related to our customers online activity and preferences, and data that might be inferred from other data we collect. Collected personal data is further processed in order to create target audiences and offer targeted content. Targeted content is always based on segments or audiences and not on our consumer customers’ individual behaviour. More information about our practice regarding cookies is available here.  

• To offer our services such as Nokian Tyres' Tire Guarantee or Nokian Tyres’ Satisfaction Promise.  

Personal data processed for this purpose includes contact information, vehicle and tire information and purchase information.  

• To organize competitions and draws for our consumer customers. 

Personal data processed for this purpose includes contact information and possible competition specific information. 

• To develop our products and services based on our customers feedback, product reviews and online activity. 

Personal data processed for this purpose includes contact information, terminal equipment identifiers, online identifiers, behavioural data, customer feedback and product reviews. More information about our practice regarding cookies is available here.  

• Fulfilling statutory obligations and any other official rules and regulations 

Personal data processed for this purpose includes any information relevant regarding a given statutory requirement.  

Legal basis for processing our consumer customer’s personal data is always one of the following:  

• Consent 

With regards to newsletter subscription, we process personal data only if a customer has given consent for it. Customers can withdraw their consent for direct electronic marketing purposes by using “unsubscribe link” at the end of the received email message.  

• Contract 

Legal basis for processing is contract when we process personal data for the purpose of organizing competitions or draws, or with regards to product guarantees where processing is necessary for a contractual relationship and enforcing the service contract.   

• Legal Obligation 

In relation to fulfilling our statutory obligations the legal basis of processing is our legal obligation.  

• Legitimate interest 

We process personal data based on our legitimate interest to develop our products and services, to provide customer service, and to market and advertise our products and services.  

To demonstrate that our legitimate interest does not cause any significant intrusion into our customer’s privacy, or any other undue impact on interests and rights, we assess the processing with balancing tests. More information on the balancing test can be requested by contacting [email protected].  

PERSONAL DATA TRANSFERS AND DISCLOSURES 

Personal Data Transfers 

As a global company, Nokian Tyres uses subcontractors and service providers to operate our business efficiently. For example, we use subcontractors to carry out campaigns and direct marketing or service providers for payment and billing management.  Furthermore, our dealers may process personal data on our behalf when you submit a guarantee claim or tire return to us through them.

The processing of personal data in relation to our subcontractors is always commissioned by Nokian Tyres and the other parties will act only on our behalf as personal data processors. Such processing is always protected with contractual arrangements to ensure that our service providers and partners process our customers’ personal data in accordance with the laws and good data processing practices.  

In a case our subcontractor or service providers is located outside the European Union (EU) or the European Economic Area (EEA) we ensure the adequate level of protection of our customers’ personal data with appropriate safeguards by using standard contractual model clauses approved by the European Commission or another valid mechanism provided under applicable legislation.

Personal Data Disclosures  

We only disclose personal data that is strictly necessary for complying with the statutory requirement. Example, when we give assistance in investigations of accidents, we need to disclose relevant information to support the investigative authorities.  

We might disclose personal data to other companies within Nokian Tyres group. This usually happens for the purposes of customer service, customer relationship management and marketing.  

In a case we sell, merge or otherwise re-arrange our business operations or assets, we need to disclose personal data to purchaser or prospective seller or buyer of such business or assets in compliance with applicable laws. In such a case we process personal data based on our legitimate interest to ensure our business continuity. In case a customer objects to such processing, the purchaser of our business may not be able to provide services anymore.  

SECURITY OF PERSONAL DATA  

We use technical and organisational measures to ensure the security of personal data from loss, misuse or other similar unlawful access. Such methods include the use of firewalls, encryption technologies and safe server premises. Access to personal data is limited on “need-to-know” basis and controlled by system access rights, as well as through granting and controlling access rights.  

In the event of a personal data breach, we will notify local supervisory authorities and everyone whose personal data may have been endangered in accordance with applicable legislation.  

DATA SUBJECT RIGHTS  

As a responsible company we want to be open and transparent on the processing of our customers’ personal data. This means we give our customers the opportunity to control the processing of personal data.  

Right of Access. Customers have the right to receive a confirmation whether we are processing their personal data, what personal data we process about them and to receive a copy of their personal data.  

Right to Rectification. In case personal data of our customers is inaccurate or incomplete, customers have the right to request rectification or completion of their data.  

Right to Restrict Processing. Customers have the right to request restriction by contesting the accuracy of their personal data. In such a situation, the processing activities are restricted for the period of time taken to verify the accuracy of personal data.  

Right to Object. Customers have the right to object to the processing of their personal data. Our customers have the right to object the processing of their personal data for the purposes of direct marketing at any time.  

Right to be Forgotten. Customers have the right to request their personal data to be erased. In some cases, there may still be an overriding purpose for processing and retaining personal data e.g. in order to fulfil legal obligations or for the warranty needs.  

Right to Data Portability. Customers have the right to request their personal data in machine-readable format in situations where we process personal data based on contract or consent. This only applies to personal data customers have provided us with.  

Right to Withdraw a Consent. Customers have the right to withdraw their consent at any time. Customers can withdraw their consent for direct electronic marketing purposes by using “unsubscribe link” at the end of the received email message.  

If customers consider that the processing of personal data infringes their rights, customers may contact the supervisory authority and lodge a complaint about our processing of personal data.  

Any questions or requests regarding above mentioned rights can be sent via email to [email protected].  

RETENTION PERIODS 

Personal data is retained as long as is necessary for the purpose they were collected for, or until we receive a request for erasure – unless we have a legal obligation to retain it for a longer period. The retention period of personal data is determined by the following criteria: 

• If a customer has a Dealer Service account with us, we will retain personal data while your account is active or for as long as needed to provide services to customer.  

• For guarantees and other product related programmes we need to retain personal data for the duration of the validity of the guarantee or programme in each specific case and in any case until any possible claims towards Nokian Tyres have expired. 
• For purposes of organizing competitions or draws, personal data will be retained until the competition has ended and all the following measures has been carried out. More information on retention periods is always provided in the competition terms. 
• When a customer has subscribed into receiving electronic direct marketing communications, we process personal data for those purposes as long as their subscription remains in force. In case a customer withdraws their consent, we will discontinue the processing of personal data and erase personal data if there is no other valid purpose for processing. 

Any questions regarding retention periods of our customers’ personal data can be sent via email to [email protected].  

REVISIONS TO THIS PRIVACY STATEMENT  

We are continuously developing our services and this privacy statement is subject to changes. Changes may also be based on changes in legislation. We recommend our customers to visit this privacy statement in regular basis in order to keep track of possible changes. 

In this privacy statement for Nokian Tyres’ whistleblowing channel, we describe the personal data that Nokian Tyres Group companies (hereinafter “Nokian Tyres” or “we”) may process in the whistleblowing channel, for what purposes we process the personal data, to whom we may disclose this information, as well as your rights regarding personal data that is processed in the whistleblowing channel.  

Nokian Tyres has a defined whistleblowing process for investigating reports made to its whistleblowing channel. Personal data of various data subjects may be processed during the investigation. Data subjects usually involve the person making a report (“the whistleblower”) and the person mentioned in a report (“the alleged wrongdoer”). Depending on the case under investigation, personal data of the investigator and witnesses may also be processed.

We are continuously developing our operations, and this privacy statement is subject to changes. Changes may also be based on changes in legislation. We recommend our data subjects to visit this privacy statement in regular basis in order to keep track of possible changes.

Protection of data subjects’ privacy is important to us. Nokian Tyres is committed to processing personal data transparently and in com­pliance with applicable da­ta pro­tec­tion laws.

 

Controller and Contact Information

The whistleblowing channel is used in all Nokian Tyres group companies. The controller for whistleblowing reports submitted in the group level channel is Nokian Tyres plc. The whistleblower may also choose to submit the report to certain local companies defined in the whistleblowing channel, instead using the group level channel. In such case the controller is the local company to whom the report is submitted.

 

Any questions regarding our privacy practices can be directed to us at:

 

Controller for group channel:

Nokian Tyres plc

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

Controllers for country-specific channels:

Nokian Heavy Tyres Ltd

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

 

Nokian Tyres Europe Operations S.R.L

c/o Nokian Tyres

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

Nokian Tyres s.r.o.

c/o Nokian Tyres

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

Vianor Oy

c/o Nokian Tyres

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

Vianor AB

c/o Nokian Tyres

Privacy

Pirkkalaistie 7

37100, Nokia, FINLAND

[email protected]

 

Purposes of Processing & Legal Basis

The purpose of the whistleblowing channel is to allow employees and external stakeholders to report concerns about a misconduct at Nokian Tyres, including violations of our Code of Conduct or other policies, without the risk of retaliation.

Purposes of processing personal data:

• Investigating reports made to the whistleblowing channel
• Preventing, identifying and   investigating   suspected criminal offences, irregularities and violations or other actions in breach of EU or national laws, or our internal policies, within a work-related context.

We will process your personal data based on the following legal grounds:

• If the subject of the whistleblowing report is a suspected violation that falls within the scope of EU Whistleblower Directive^[1] (“Directive”), the legal basis for processing is legal obligation.
• If the subject of the whistleblowing report is a suspected violation that falls out of the scope of the Directive, the legal basis for processing is our legitimate interest to monitor compliance with applicable laws and Nokian Tyres’ Code of Conduct and other guidelines. In this respect, we will always determine case by case whether our interests are not overridden by the interests, fundamental rights and freedoms of the data subjects involved.
• As a general rule, no special categories of personal data are processed in the whistleblowing channel. However, if under exceptional circumstances, the report and investigation relate to special categories of personal data, the legal basis for such processing is that it is necessary for the purposes of carrying out the obligations and exercising the specific rights of Nokian Tyres, or that the processing is necessary for the establishment, exercise or defence of legal claims.

 

Sources & Categories of Personal Data

Initially personal data is primarily obtained through the whistleblowing channel (via a specific whistleblowing service). Depending on the case under investigation, the whistleblowing team may request information and expertise from other individuals or authorities within or outside Nokian Tyres.

In most cases the personal data processed in connection to the whistleblowing channel includes:

• Data received via whistleblowing report such as name and contact details of the whistleblower (unless report is made anonymously) and the alleged wrongdoer, and a description of the suspected misconduct. Due to the nature of the whistleblowing channel and varying case contexts, the received data can vary significantly on each case. Depending on the received report, processed personal data can also include special categories of personal data.
• Data obtained through investigative measures such as employment information, records of working hours, witness testimonies and case relevant information from public registers or other public or internal information.

The whistleblowers are instructed to not include any non-relevant personal data in the report, such as health status, political or religious beliefs or sexual orientation.

 

Personal Data Transfers and Disclosures

 

Personal data transfers

The whistleblowing service we use for our whistleblowing channel is managed by our external subcontractor Navex WhistleB, which processes personal data on behalf of Nokian Tyres to the extent necessary to provide the service related to the whistleblowing channel. In this case, the data processing activities apply to the personal data that emerges in connection with the whistleblowing report and any related clarifications and communication.

The investigation of a report made is primarily outsourced to the group parent company and the whistleblowing team. Depending on the case and provided that it is necessary to conduct the investigation, we may also involve other expert individuals from within or outside the group companies to whom the  identity of the whistleblower (if the report has not been made anonymously) or other persons referred to in the report may be provided (subject to local laws). Such expert individual is also bound to confidentiality.

The processing by subcontractors is protected with contractual arrangements to ensure that our subcontractors process personal data in accordance with the laws and good data processing practices to maintain high integrity of the investigation.

Personal data processed in connection with the whistleblowing channel is not, in principle, transferred outside the European Union or the European Economic Area. If a data transfer is necessary, for example in connection with an investigation related to a whistleblowing report or other follow-up measures, it will only be carried out if the conditions for data transfer set by data protection regulations are met.

 

Personal Data Disclosures

In principle, personal data related to the whistleblowing channel is not disclosed by Nokian Tyres to third parties, except when the processing, clarification or bringing under investigation of the whistleblowing report or, for example, a request for information from an authority necessarily requires it.

In these cases, the data may be disclosed, within the limits permitted by law, to the preliminary investigation or other competent authorities insofar as is justifiably necessary. Before disclosing data, we make sure that there is a legal basis for the disclosure, and that the disclosure takes place in compliance with the applicable regulatory obligations. 

In a case we sell, merge or otherwise re-arrange our business operations or assets, we need to disclose personal data to purchaser or prospective seller or buyer of such business or assets in compliance with applicable laws. In such a case we process personal data based on our legitimate interest to ensure our business continuity.

 

Security of Personal Data

Nokian Tyres´ whistleblowing channel is based on a secure and encrypted platform managed by an external service provider, Navex WhistleB, which ensures the appropriate data protection and information security of the whistleblowing channel.

To ensure the anonymity of the whistleblower sending the message, the service provider deletes all meta data, including IP addresses. The whistleblower also remains anonymous in the subsequent dialogue with responsible receivers of the report.

Access to messages received through our whistleblowing channel is restricted to members of the whistleblowing team with the authority to handle whistleblowing cases. Members of the whistleblowing team are appointed by the President and CEO. The user rights for accessing systems that contain personal data are personal, and the use of the rights is monitored. Individuals that process personal data are bound by, in addition to the statutory obligation of secrecy, a separate non-disclosure agreement. Their actions are logged in the whistleblowing channel.  

In the event of a personal data breach, we will notify local supervisory authorities and everyone whose personal data may have been endangered in accordance with applicable legislation.

 

Data Subject Rights

As a responsible company we want to be open and transparent on the processing of personal data. This means we give our data subjects the opportunity to control the processing of personal data. However, because of the nature of the processing in whistleblowing investigations, we have the right to derogate from exercising the data subjects’ rights in certain situations based on legal grounds.

 

Right of Access. Data subjects have the right to receive a confirmation whether we are processing their personal data, what personal data we process about them and to receive a copy of their personal data. Legislation, the rights and freedoms of other individuals and other special grounds my limit your right to access some of your personal data. The right to access the personal data can be partially or completely restricted if and to the extent that is necessary and proportionate to ensure the accuracy of the report or to protect the identity of the whistleblower, or if providing the information could hinder the investigation. 

Right to Rectification. In case personal data of our data subjects regarding the whistleblowing process is inaccurate or incomplete, data subjects have the right to request rectification or completion of their data.

Right to Restrict Processing. Data subjects have the right to request restriction by contesting the accuracy or lawfulness of their personal data. In such a situation, the processing activities are restricted for the period of time taken to verify the accuracy of personal data. The right to restriction of processing is assessed on a case-by-case basis. In cases which are likely to have legal effects on the data subject, the data may still be processed, subject to the establishment, exercise or defense of legal cases, compliance with laws or for the protection of the rights of another natural or legal person or, despite the request for restriction of the data subject.

Right to Object. Data subjects have the right to object to the processing of their personal data, when the processing is based on our legitimate interest. The objections are assessed on case-by-case basis and we may restrict the data subjects’ right to object the personal data processing, for instance, for the establishment, exercise or defence of legal claims.

Right to be Forgotten. Data subjects have the right to request their personal data to be erased. In some cases, there may still be an overriding purpose for processing and retaining personal data e.g. to fulfil legal obligations or for another legal basis, such as the establishment, exercise or defence of legal claims.

If data subjects consider that the processing of personal data infringes their rights, they may contact the supervisory authority and lodge a complaint about our processing of personal data.

 

Any questions or requests regarding above mentioned rights can be sent via email to [email protected].

 

Retention Periods

Personal data is retained as long as is necessary for the purpose they were collected for, or until we receive a request for erasure – unless we have a legal obligation or legitimate interest to retain it for a longer period. We erase or anonymize the data when their retention period expires.   

The personal data will be processed and retained as long as necessary to process and investigate the whistleblowing report, or, if applicable, as long as necessary to initiate sanctions or to meet any legal or financial requirement or to exercise or defence of legal claims. In any case, if judicial or disciplinary proceedings are initiated, the personal data provided will be kept until those proceedings are definitively closed. If not otherwise determined in local applicable laws, Nokian Tyres retains all received whistleblowing reports and their related material, which have been seen as significant for the investigation or conclusion of investigation, including any possible summaries or document listings, for five years from the date on which the case has been resolved or deemed not to require further investigative measures.

 

Any questions regarding retention periods of our data subjects’ personal data can be sent via email to [email protected].

 

 

[1] Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law

This Privacy Statement describes how Nokian Tyres process the personal data of website and social media acccount visitors. Protection of privacy of the website and social media acccount visitors‘is important to us. Nokian Tyres is committed to processing personal data transparently and in compliance with applicable data protection laws.

We are continuously developing our websites and services, and this privacy statement is subject to changes. Changes may also be based on changes in legislation. We recommend you to visit this privacy statement in regular basis in order to keep track of possible changes.

 

Contents of this statement:

A. Information on data protection when using our website
B. Information on data protection for our social media accounts

 

A. Information on data protection when using our website 

I. Controller and contact information
Nokian Tyres plc is the controller of the personal data of our website visitors. Any questions relating to the data protection of our website visitors can be directed to us:

Nokian Tyres plc
Privacy
Pirkkalaistie 7
37100, Nokia, FINLAND

[email protected]

II. Data processing during informational visits to our website

As soon as you visit our website, information from your computer system and browser is automatically transmitted to us:

- Information about the browser type, language and its version
- Your operating system
- IP address
- Date and time of the request, including pages accessed
- Access status or http status code and amount of data transferred
- Website from which you access our website
 
This data is automatically stored in the log files. It is not merged with other personal data.

The purpose of collecting and storing this data is to make the website available to our visitors and to ensure the functionality and security of our IT systems.

To provide this website, we use the web hosting service of Google's Finnish data center Hamina in Finland. Cloudflare CDN is also used. In connection with the hosting, the personal data is processed by the web host on our behalf, which is generated when the website is used. We have concluded a data processing agreement with our web hosts.

The legal basis for the temporary storage of the data in the log files  is legitimate interest. The website cannot be accessed and made available without the collection of the aforementioned data, so that there is a legitimate interest in technically enabling the use of the website. 
The data is deleted as soon as it is no longer required for the purposes for which it was collected. If data is used to provide the website, it will be deleted when our website is closed. The data stored in log files is deleted after 7 days at the latest.

 
III. Cookies

Cookies are used on our website. Detailed information about what cookies are and which cookies we use and for what purpose can be found in our cookie policy.

IV. Inquiries and feedback and contact by e-mail

Under the website heading "Enquiries and feedback", we provide a contact form that you can use to contact us on various topics. It is also possible to contact us via the e-mail addresses included on the website. We collect the following data to process your request:

- Subject
- Feedback or content of the request*
- Your name*
- E-mail*
- Telephone number
 
The fields marked with * are mandatory to process your request.

We store the personal data you provide to process your request or to contact you. This is also our legitimate interest in processing this data. Your personal data will not be passed on to third parties.

The legal basis for the collection of the data listed for the form or contact by e-mail is legitimate interest. If the request via form or e-mail is aimed at concluding a contract, the contract is also the legal basis.

We only store the data collected using the inquiry and feedback form or email for as long as is necessary to process the inquiry. The data will then be deleted immediately, unless there is a legal obligation to retain it or a legal right to retain it. In this case, the data will only be processed for as long as necessary and as data-efficiently as possible.

 

V. Registration of the tire warranty

We offer a special tire warranty for buyers of certain tires for a certain period of time. One of the conditions of the warranty is registration. Further information can be found here. You can register after purchase (tire warranty registration) or in some countries also before purchase (warranty pre-registration) on our website.  

The following data is collected for registration:

- First name*, last name*
- E-mail*
- Telephone number
- Country*, postcode*
- License plate number*
- Tire model*, tire size*, inch*
- Newsletter subscription

Fields marked with * are mandatory. The following data is also stored at the time of registration:

- IP address of the registrant
- Date and time of registration

We collect the aforementioned data in order to conclude and process the warranty contract. The data will not be passed on.

The legal basis for processing the personal data provided in the form, the IP address and the date and time is the entering into and performance of the warranty contract. The processing of your personal data in connection with the newsletter registration is based on consent.

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. This is the case if the data is no longer required for the performance of the contract. Even after conclusion of the contract, it may be necessary to store the personal data of the contractual partner to comply with contractual or legal obligations. The data is regularly deleted three years after the end of the calendar year in which the guarantee expires. Registered buyers can object to processing under the guarantee at any time. It is then no longer possible to grant a guarantee.

 

VI. YouTube videos

Some of our pages include content from YouTube, which can be viewed directly on our site by clicking on a link or by clicking on the video. These videos are intended to make our website more attractive for our users and improve our content. YouTube is a service of YouTube, LLC, a subsidiary of Google Inc, USA.

The extended data protection mode for embedding YouTube videos has been activated on this website so that no information about visitors to our website is transmitted or stored if they do not watch the video. No cookies are set on your device when you watch the video either.

When a YouTube video is viewed, information about your use of this website is transmitted to a YouTube server as part of the YouTube service and shared with the Google advertising network Doubleclick. The following data may be transmitted in this way (regardless of whether YouTube provides a user account through which you are logged in):

- Browser type/version
- Operating system used
- Host name of the accessing computer (IP address)
- Time of the server request
- Frequency of page views
- Video viewed
 
The transmission to YouTube and Doubleclick takes place on servers of Google LLC. in the USA (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Due to the certification of Google LLC within the EU-US Data Privacy Framework, the data transmission is permitted.

If you are logged in to YouTube, your data will be assigned directly to your account. If you do not wish your data to be associated with your YouTube profile, you must log out before clicking on the video. YouTube stores your data (even for users who are not logged in) as usage profiles and uses them for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

The legal basis for data processing is consent. By clicking on the video, you consent to the transfer of data to Google.

Further information on the purpose and scope of data collection and its processing can be found in Google's privacy policy (YouTube, as part of Google, does not have its own). There you will also find further information on your rights in this regard and setting options to protect your privacy.

- Google terms of use: https://policies.google.com/terms 
- Google privacy policy ("Google Privacy Policy"): https://policies.google.com/privacy
- YouTube terms of use: https://www.youtube.com/t/terms

VII. Dealer Locator 
On our website, we also offer the option of searching for the right retailer to buy our products. You can search for the right retailer either via the location on a Google Maps map or via an address, city or zip code.

We obtain a list of available retailers who sell the selected product from the Hatch service, which is part of PriceSpider: https://www.pricespider.com/privacy-policy-2021/.

We rely on the most data-saving integration of Google Maps, which is only available after activation, excludes storage and personalization and prevents the collection of user data. However, it cannot be ruled out that personal data will still be transferred to Google in the USA when the map is used. Further information on data processing by Google: https://policies.google.com/privacy.

We process personal data such as address, city, zip code or location exclusively for the provision of the dealer search. This data is not stored.

VIII. Statistical Data on purchases from retailers

To optimize the processes on our website, we collect statistical data in connection with purchases on our retailers' websites that you have accessed via our website.

If you have selected a suitable product and searched for a suitable seller via the retailer search, you can continue shopping on our retailer's website (e.g. Vianor) with one click. By redirecting you, the retailer can see that you have reached their site via our retailer search. If you complete the purchase, this information becomes part of the retailer's order database. Our dealers return the number of successful sales that came in via our dealer search to us in the form of statistical data. Identifying data is not passed on. Information on data processing by the retailer can be found in the respective privacy policy.

The legal basis for the processing of statistical data is our prevailing legitimate interest in the traceability of the sales process.

You have the right to object to the processing. However, a successful objection to us requires you to provide us with your personal data, as we do not have the statistical data in a manner that is identifiable to us. Please note that you also have the right to object to the retailer with whom you have concluded a purchase contract for one of our products.

The statistical data is initially stored in pseudonymized form. When the retention periods at our dealers expire, the data is automatically anonymized.

IX. Google reCAPTCHA

We also use reCAPTCHA data matching from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") on our website to protect us from bots and other spam techniques when submitting forms, in particular the contact form and the tire guarantee. This also constitutes our legitimate interest in the processing of this data . The service also includes sending the IP address and any other data required by Google for the reCAPTCHA service to Google; the transmission of personal data to Google servers in the USA cannot be ruled out. Due to the certification of Google LLC within the EU-US Data Privacy Framework, the transfer of data to the USA is permitted. The legal basis for the CAPTCHA query is our overriding legitimate interests. 

The cookie set by reCAPTCHA is deleted at the end of the session. How long the data transmitted to Google in the USA is stored is unclear. Google does not make any statements on this. Further information on Google reCAPTCHA and Google's privacy policy can be found at: https://policies.google.com/privacy.

 
X. Google Ads 
We use the Google Ads service to serve ads to you about our products and services and those of our partners. When visitors come to our website through a Google ad, Google Ads tells us how they came to our website. We can only review this information in an aggregated form.

Any further processing of the data by Google, such as processing of users' data on Google.com for personalized advertisement, is the sole responsibility of Google. Further information on Googles processing can be found at: https://policies.google.com/privacy.

If we wish to carry out further performance measurement of our advertising campaign, we process our visitors' data using Google Analytics, which is explained in the following section.

 

XI. Google Analytics

In addition to our explanations in our cookie policy, the following applies regarding Google Analytics:

We use Google Analytics to analyze and subsequently optimize the use of our website. Google Analytics is provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), a subsidiary of Google LLC. Google processes the data on our website usage on our behalf and is contractually obliged to guarantee the confidentiality and security of the data. We have accordingly concluded an order processing agreement with Google.

During your visit to the website, the following data is transmitted to Google if you have consented to this:

- Pages accessed
- Achievement of "website goals" (e.g. use of the contact form or registration for the newsletter)
- Actions on the website
- Approximate location (country and city)
- Abbreviated IP address
- Technical information: Browser, internet provider, end device, screen resolution
- Source of origin of the visit
- Randomly generated user ID
 
According to the provider, IP anonymization takes place by default, so that the IP address of Google users within member states of the European Union or in other signatory states to the Agreement on the European Economic Area is shortened beforehand. It is therefore no longer possible to associate the data with the accessing user.

The aforementioned data is transferred to Google servers in the USA. Due to the certification of Google LLC within the EU-US Data Privacy Framework, the transfer of data to the USA is permitted. 

Analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer. Accordingly, Google compiles reports on website activity for us.

The legal basis for the processing of personal data using cookies for analysis purposes is your consent. 

In addition, on the basis of our legitimate interests, we merge your data collected based on your consent on this page using Google Analytics with other data collected by Google Analytics on the websites of our corporate group (in particular Vianor). Our legitimate interest lies in optimizing our web offerings for the sale of our products, including via our subsidiaries. To this end, we would like to merge and evaluate the data collected by Google Analytics based on your consent on the basis of our legitimate interests.

The cookies containing the random ID are stored in your web browser for a period of two years. The recorded data enables the evaluation of pseudonymous user profiles, which are automatically deleted after 14 months.

You can object to the storage or setting of a cookie at any time by deleting the cookie and rejecting it the next time cookies are requested.

 

XII. React & Share Plugin

To improve the reach of our articles and our brand, we use the ReactandShare service from "React & Share Oy". Personal data is only sent to Facebook, Twitter, WhatsApp, LinkedIn, Pinterest, Google+, Telegram or your email program when you click on a share button. No personal data is sent to the aforementioned providers before this. React & Share also allows the user to give immediate feedback to specific articles and news. Therefore, fonts and the plugins of React & Share are loaded which leads to the transmission of the visitor's IP-address. The interaction with the React & Share Plugin can be evaluated and leads to statistical data. The service provider acts on our behalf and is bound by our instructions. Accordingly, we have concluded a data processing agreement with "React & Share Oy".

The legal basis for processing is legitimate interest. We do not store any personal data. We can only view statistical evaluations of whether and which articles and posts you have given feedback to and shared with which social media network.

 

XIII. Rights of the data subjects

As a responsible company we want to be open and transparent on the processing of our website visitor's personal data. This means we give our website visitors the opportunity to control the processing of personal data.

Right of Access. You have the right to receive a confirmation whether we are processing your personal data, what personal data we process about you and to receive a copy of your personal data. 
Right to Rectification. In case your personal data is inaccurate or incomplete, you have the right to request rectification or completion of their data.

Right to Restrict Processing. You have the right to request restriction by contesting the accuracy of your personal data. In such a situation, the processing activities are restricted for the period of time taken to verify the accuracy of personal data. 
Right to Object. You have the right to object to the processing of your personal data. You have the right to object the processing of your personal data for the purposes of direct marketing at any time.

Right to be Forgotten. You have the right to request your personal data to be erased. In some cases, there may still be an overriding purpose for processing and retaining personal data e.g. to fulfil legal obligations or for the warranty needs.

Right to Data Portability. You have the right to request your personal data in machine-readable format in situations where we process personal data based on contract or consent. This only applies to personal data you have provided us with.

Right to Withdraw a Consent. You have the right to withdraw your consent at any time. You can withdraw your consent for direct electronic marketing purposes by using "unsubscribe link" at the end of the received email message. 
 
If you consider that the processing of personal data infringes your rights, you may contact the supervisory authority and lodge a complaint about our processing of personal data.

Any questions or requests regarding above mentioned rights can be sent via email to [email protected].

 

B. Information on data protection for our social media accounts

We operate social media presences to provide additional information and a further opportunity for direct interaction with business partners, customers and interested parties.

These include Facebook, Instagram, LinkedIn, Twitter/X and YouTube.

We use the technical platforms and services of the respective providers for these information services. We are not the original provider of these platforms. The aforementioned providers - with the exception of the provider of Facebook, with whom we are jointly responsible for data processing as part of the web analysis tool Page Insights - process your personal data on their own responsibility.

We would like to point out that the use of our social media accounts and their functions is your own responsibility, especially when interacting by commenting, sharing and liking. The providers of these platforms use cookies that are stored on your device even if you do not have your own user account with the respective provider or are not logged into the respective profiles while visiting our site. These cookies enable the providers to create user profiles based on your preferences and interests and to display customized advertising (within and outside the respective social media platform). The cookies remain on your device until you delete them. For details on the collection and storage of your personal data as well as the type, scope and purpose of its use by the respective platform operator, please refer to the data protection declarations of the respective social media platform.

- Facebook: https://www.facebook.com/privacy/policy/ 
- Instagram: https://help.instagram.com/519522125107875 
- LinkedIn: https://www.linkedin.com/legal/privacy-policy 
- Twitter/X: https://twitter.com/en/privacy 
- YouTube: https://policies.google.com/privacy?hl=en 

We are not familiar with and have no influence on the way in which the respective platform operators use your data from your visit to our profile pages and interaction with our posts for their own purposes, how long this data is stored and to what extent data is passed on to third parties and transferred to countries outside the European Union. For the transfer of data from the European Union to the USA under the EU-US. Data Privacy Framework (successor to the former EU-US Privacy Shield), the European Commission issued an adequacy decision on July 10, 2023. The platform operators are certified under this EU-US. Data Privacy Framework.

As the operator of the social media profile pages, we can only view the information stored in your public profile, and only if you have such a profile and are logged into it while interacting with our respective social media profile page.

In addition, the provider of Facebook, Meta Platforms, provides us with anonymous usage statistics (Page Insights), which we can use to improve the user experience when visiting our profile page on this platform. Even though we are jointly responsible with Meta Platform for data processing as part of the web analysis tool Page Insights, we do not have access to the usage data that Meta Platforms collects to compile these statistics. Meta Platforms has undertaken to us to assume primary responsibility under the GDPR for the processing of this data, to fulfill all obligations under the GDPR regarding this data and to provide you, as the data subject, with the essentials of this obligation. Further information on the content of our joint controllership agreement with Meta Platforms Ireland Ltd can be found at https://www.facebook.com/legal/terms/page_controller_addendum.

We use the opportunity to present our company on the social media platforms to provide information about our company, share our job vacancies and activities and get in touch with users. These purposes also constitute our legitimate interest in data processing (the legal basis for data processing).

If you wish to contact us, we will only process the personal data that you provide to us yourself (e.g. name, e-mail address). This data is used exclusively for the purpose of responding to your request. The legal basis is therefore consent and contract . This data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. All public posts by you on one of our social media accounts remain in the timeline indefinitely, unless we delete them due to an update of the underlying topic, a legal violation or violation of our guidelines or you delete the post yourself.

You can object to the processing of your personal data on the social media platforms by us at any time. To do so, send us an informal email to [email protected]. We will then no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the establishment, exercise, or defense of legal claims.

To exercise your rights as a data subject, you can contact us or the respective provider of the social media platform. If one party is not responsible for responding or must receive the information from the other party, we or the provider will then forward your request to the respective partner. Please contact the operator of the social media platform directly for questions about profiling and the processing of your data when using the website. If you have any questions about the processing of your interaction with us on our site, please write to the contact details we have provided above.