1. GENERAL
Nissens Automotive A/S including all other companies within the Nissens Group (hereafter Nissens) are committed to ensuring the confidentiality, integrity and protection of information from our employees, customers, suppliers and other business partners, including their personal data.
When the above and following paragraphs are referring to the “data subject”, it means the person whose personal data is involved.
2. PERSONAL DATA COLLECTED AND PROCESSED BY NISSENS
Nissens is responsible as a data controller when collecting personal data.
a. General
Nissens collects personal information, including information about names, titles, addresses, telephone numbers and e-mail addresses related to employees, job candidates, customers, suppliers, third parties, their owners and contact persons.
Nissens can collect and process data about customers and their customers’ vehicles and their registration numbers. Nissens can collect and process data about mechanics’ training sessions and certifications.
Nissens can collect information about passports (copy of passports) and civil registration numbers, but limited to where necessary according to legislation or based on relevant purpose. This nature of sensitive information will be stored under intensified security and control.
b) On digital platforms
On Nissens’ website, in Nissens’ webshop and via newsletters (only with consent) a range of information is collected:
- Which sites the visitor has been looking at, when, and thereby the visitor’s electronic tracks
- Which browser the visitor is using
- Which IP address the visitor has
- Which username is applied by the visitor
- Cookies
No other information is collected, unless transparent notification is provided to the visitor.
For further information regarding cookies and cookie consent please see the cookie declaration available on all Nissens webpages.
On Nissens social media
Nissens maintains accounts on Facebook, Instagram and LinkedIn, where registered users can leave messages, observe, recommend or ‘like’. Such activity may result in the transfer of personal data by the users themselves.
The ability to maintain an account on LinkedIn is provided to us by LinkedIn Ireland Unlimited Company. Wilton Place, Dublin 2, Ireland (LinkedIn).
Beside the account on the LinkedIn platform Nissens also use a marketing tool called LinkedIn Insight Tag. This tool link Nissens’ LinkedIn marketing account to the Nissens website. It allows Nissens to assess the effectiveness of the ads displayed on LinkedIn in relation to specific actions the user has taken on the site. Data where Nissens is the data controller, such as member pseudonym, IP addresses, time stamp, URL device and browser characteristics are entrusted to LinkedIn for processing or to share it with further processors, also in third countries.
In relation to such data Nissens and LinkedIn are acting independently as data controller and are not joint controllers.
Nissens and LinkedIn are however joint controllers of the personal data processed in connection with the statistics of our page on the platform. LinkedIn are responsible in terms of compliance with the obligations to fulfill its duty of information towards users and enabling them to exercise their rights. LinkedIn are also responsible for providing appropriate technical and organisational measures, You can find the co-management agreement with LinkedIn here: LinkedIn Joint Controller.
LinkedIn acts as a controller or co-data controller for the platform that processes data, or uses further processors, also in third countries.
For more information on the security measures used by LinkedIn LinkedIn Security
More on LinkedIn’s data processing: LinkedIn Privacy
The ability to maintain an account on Facebook and Instagram is managed by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (Meta).
Beside the accounts Nissens also use a marketing tool called Facebook Pixel. This tool link Nissens Facebook marketing account to the Nissens website. It allows Nissens to assess the effectiveness of the ads displayed on Facebook in relation to specific actions the user has taken on the site. No personally identifiable data are received from Facebook about individuals by using this tool. With regard to personally identifiable data, i.e. names, e-mail addresses and telephone numbers Nissens are the data controller and entrust it to Meta for processing or to share it with further processors, also in third countries.
In relation to other data regarding individuals and their activities on the Nissens website, e.g. visits to the website or purchases of products – Nissens and Meta are joint controller of this data; the scope of joint processing includes the collection of the data and the transfer of the data to Meta,
The joint control of the data includes that each party are responsible for the tasks associated with the treatment they each undertake. In contrast, any other processing of personal data in connection with our Facebook/Instagram page for which there is no joint specification of purposes is carried out by Nissens or Meta Platforms separately, as independent controllers.
As part of the joint control, Meta Platforms is responsible for, among other things, the exercise of the rights the data subjects under Articles 15 to 21 of the GDPR by implementing appropriate technical and organisational measures to ensure the security of the processing in accordance with Article 32 GDPR, and carries out notifications in the event of a personal data breach in accordance with Articles 33 and 34 of the GDPR.
Further information on the processing of data in connection with page statistics on the platforms, including the division of responsibilities between the joint controllers can be found here: Facebook terms.
More on data processing by Meta:
Facebook Business Tools Regulations
c) HR
Nissens does not collect personal data, which has the character of highly sensitive personal information, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, biometric data, genetic data, sexual orientation, criminal record or social relationships.
Nissens only collects personal information, which has the character of semi-sensitive personal information for clear, defined and transparent purposes, such as trade union memberships, health information and other strictly relevant information pertinent to the employer–employee relationship and responsibilities.
Concerning job candidates applying for or in consideration for job positions at Nissens as well as retired employees, Nissens collects personal information, such as names, civil registration numbers, titles, addresses, telephone numbers, e-mail addresses, CVs, applications, education documentation, transcripts of records, statements/recommendations, personality tests, photos and movies (where the data subject is featuring), summaries of performance reviews about the data subject (employees), salary and tax information (when required by legislation), information regarding pension, social security as well as travel information. In these cases, the data is under intensified confidentiality and control within Nissens’ HR and Finance Departments.
3. LEGAL BASIS
Nissens is only collecting and processing personal information on legal grounds. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:
a) The processing is necessary for the performance of a contract to which the data subject is a party in accordance with GDPR, Article 6(1)(b), the first indent.
b) The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract in accordance with GDPR, Article 6(1)(b), last indent.
c) The processing is necessary to comply with applicable legislation in accordance with GDPR, Article 6(1)(c).
d) The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in accordance with GDPR, Article 6(1)(f).
e) The legal basis for the processing of such personal data is consent, in accordance with GDPR, Article 6(1)(a). the data subject can withdraw the consent at any time by contacting Nissens via the contact details provided in this Policy. If the data subject withdraw the consent, the personal data processed will be deleted, unless it can or must be processed in order to comply with legal obligations.
When Nissens process personal data based on our legitimate interests herein, cf. section 4.1(d), our legitimate interests stem from our interest in handling and safeguarding our role as a professional and to create maximum value for our customers and users. Our legitimate interests pursued namely consist of our interest in operating efficient, relevant and correct marketing and sales activities and in delivery of our goods in a secure, professional and efficient way.
We ensure on an ongoing basis by conducting ad hoc assessments, that our processing under this legal basis is limited to what is necessary, proportionate and has the most limited privacy impact when taking the legitimate interests into account. If a data subject-irrespective of the reason - object to this assessment or wish not to have your data processed for our legitimate interests, please contact Nissens so we can accommodate such a request.
Consent
If a consent is necessary due to legislation, Nissens collects a clear and transparent consent from the (coming) data subject. The consent can be withdrawn as easily, as it is given. See also clause 9.