(Status: July 2023)
Continental Automotive Technologies GmbH
Vahrenwalder Strasse 9
30165 Hanover
Telephone: +49 511/938-01
Fax: +49 511/938-81 770
Email : info@vdo.com
Continental Automotive Technologies GmbH
Data Compliance
Vahrenwalder Strasse 9
30165 Hanover
Email: dataprotection@conti.de
The State Commissioner for Data Protection Lower Saxony
Barbara Thiel
Prinzenstrasse 5
30159 Hanover
Telephone: +49 (0511) 120 45 00
Fax: +49 (0511) 120 45 99
Email: poststelle@lfd.niedersachsen.de
The scope of the processing of personal data by CONTINENTAL in connection with the provision of the VDO Fleet App depends largely on the services and functionalities offered via the respective app.
In principle, CONTINENTAL only collects and processes personal data to the extent that this (i) is necessary for the fulfillment of the contract or the provision of the agreed services and functionalities between the app user and CONTINENTAL (Art. 6 Para. 1 lit. b GDPR) or (ii ) if data is required for the functionality of the app within the framework of legitimate interests and the user's interests in protecting his personal data do not prevail (Art. 6 Para. 1 lit. f GDPR).
Depending on the services or functionalities provided via the app, the following types of data in particular can be processed:
Continental Automotive GmbH provides the smartphone application "VDO Fleet App". No additional hardware is required to use the application in connection with a tachograph from generation 4.1 and the connection is established using the Bluetooth protocol.
The VDO Fleet app allows you to download the legally required tachograph data (DDD data format) as well as upload and archive this data in Continental's tachograph management solution "VDO Fleet - Tachograph Management". In this way, the user ensures that the necessary data is loaded at regular intervals and stored in compliance with the law using the “VDO Fleet” archiving system. The user also has the option of logging into the VDO Fleet System within the application and using it on the go. A valid VDO Fleet contract is required to use the above functions.
Reminders " function to monitor the prescribed download intervals via the VDO Fleet System , so that he does not miss an appointment.
Furthermore, the user has the option of using the "Maps" function in connection with the VDO Fleet System. The service offered allows you to keep track of the position of the fleet vehicles (telematics device required for this) in order to be able to react in the event of events during the transport process.
If users provide further data as part of the VDO Fleet App or store/upload it into the VDO Fleet App to use further services and/or functionalities, this data will only be processed to the extent that this is necessary to provide the respective services and functionalities.
The legal basis for such processing is Art. 6 Para. 1 lit. b GDPR (performance of contract). The provision of data is always voluntary. If data required for the provision of the services / functionality offered is not provided (e.g. data required to activate the app), there may be restrictions in the provision of services or services may not be provided at all.
Insofar as CONTINENTAL provides the option of registering for newsletters or granting marketing and advertising consent via the VDO Fleet App, the following applies:
In order to be able to check whether the owner of the e-mail address provided in this context agrees to receive newsletters and/or advertising, we send an automated e-mail to the e-mail address provided after the first registration step. Only after confirming the registration link in the confirmation e-mail do we include the e-mail address provided in our mailing list (so-called double opt -in).
Please note that you can unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the newsletter. Once you have given marketing and/or advertising consent, you can revoke it at any time with effect for the future (see below).
Insofar as the VDO Fleet App collects and processes location/navigation data for the purpose of providing services and/or functionalities, the following applies:
The VDO Fleet App only processes location/navigation data if the user has enabled access to the location data on his or her mobile device. The approval is automatically requested during the installation of the VDO Fleet App via the operating system of the respective end device and can be changed again after installation - depending on the respective end device - via the settings.
In principle, location data is only used by the VDO Fleet App to the extent that this is necessary to fulfill the respective services and/or functionalities of the VDO Fleet App (e.g. for this purpose we use the map service installed on your end device; if no map service is installed on your end device, You will be forwarded to an internet-based map service, which you are free to decide how to use. The provider of the map service processes this transmitted data on his own responsibility and for his own purposes (possibly for product improvement, development of new products, for advertising purposes including the provision of personalized advertising from third parties We have no influence on this. Information on the processing of data by the provider of your map service can be found in the data protection notices of the respective provider; these can be accessed via the app of the respective map service provider or on the Internet.
If CONTINENTAL provides a contact form in the VDO Fleet App, the following applies:
Personal data from users that they make available via a contact form in the VDO Fleet App (e.g. surname, first name, address, company, e-mail address or time of the transmission) are processed for the purpose of processing the respective request or the respective user request. Insofar as the data is processed for the purpose of fulfilling a customer order or a customer request, the legal basis for the processing is Art. 6 Para. 1 lit. b GDPR. If consent is given, Art. 6 Para. 1 lit. a GDPR legal basis for processing.
The collection and processing of technical device and communication data is necessary to provide the VDO Fleet App or the provision of the services and functionalities available via the apps. In order to provide our services and functionalities, the following technical data and information in particular are processed:
|
- IP address |
- Date and time of the request |
|
- Device ID, e.g. IMEI [1], IMSI [2], mobile phone number or MAC address for WLAN use |
- Time zone difference to GMT |
|
- device type |
- Content of the request (requested service / functionality) |
|
- Device-specific settings |
- amount of data transferred |
|
- App settings |
- Message whether data exchange was successful / complete |
|
- App Properties |
- Crash app / error message |
To the extent permitted by applicable law, CONTINENTAL reserves the right to process personal user data (including location data) in a de-personalized form for the purposes of product improvement, product and IT security and to ensure product and service quality. "De-personalized" means that data can no longer be directly traced back to specific users. For this purpose, CONTINENTAL processes personal data in order to generate de-personalized data sets, which are then used to improve CONTINENTAL's products and services.
The legal basis for such processing is Art. 6 Para. 4 GDPR (change of purpose) and
Art . 6 Para. 1 lit. f GDPR (legitimate interests). CONTINENTAL's legitimate interests lie in using de-personalized data to meet the high expectations of its users in the provision of high-quality services and services, to improve products and services, to ensure product and IT security and to meet the demand for newly developed, innovative solutions and/or services into account.
To protect the interests of users - in addition to de-personalization - additional precautions and measures for data security are taken and implemented as required, e.g. strict data access restrictions, restrictions on data use, security measures, retention periods and data economy principles, such as the exclusive collection of relevant data.
SYSTEM / CRASH SECURITY
To ensure the system and crash security of our app, we reserve the right to use the analysis and monitoring tool Firebase. The service provider is Google Inc. Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for the European region.
Insofar as Firebase is used, this is only done for crash analysis as well as a related analysis of APP usage on an anonymous or aggregated basis; we use the analyses exclusively for the purpose of improving the VDO Fleet APP. The legal basis is Art. 6 para. 1 lit. f DSGVO (legitimate interests); the legitimate interest is the ensuring system security and improving the VDO-FLEET-APP in this respect. Insofar as the service provider Google processes data for the aforementioned purpose, if applicable also in the USA, this is currently done on the basis of the so-called standard contractual clauses of the EU Commission (Art. 46. para. 2 and 3 DSGVO), as well as on the basis of the new Data Protection Framework. Further information from Google on data protection at Firebase can be found at https://firebase.google.com/terms/data-processing-terms.
When providing our app services, we sometimes use third-party service providers who can work for us as part of the service provision. These service providers may come into contact with personal data as part of the provision of services and represent third parties or recipients in the sense of. GDPR. If necessary, corresponding data processing contracts are available (Article 28 GDPR). As far as third parties should be involved in a processing of data outside of a data processing agreement, we ensure that this is carried out exclusively in accordance with the requirements of the GDPR and only if there is an appropriate legal basis for doing so.
We currently use the following service providers/services to provide the VDO Fleet App: pendo.io Inc.[3]
* * *
[1]IMEI = International Mobile Equipment Identifier
[2]IMSI = International Mobile Subscriber Identity
[3] pendo.io Inc. , 150 Fayetteville St., Raleigh, NC 27601, USA; Please note: pendo.io only processes pseudonymised, aggregated data. The data is processed and stored within the EEA. In addition and as a fallback, the standard contractual clauses of the EU Commission (according to Implementing Decision (EU) 2021/914) also apply. In addition, Continental has implemented specific technical security measures to prevent unauthorized access to data, especially from outside the EEA.