Introduction

This privacy policy outlines how the Haldex Group (with Haldex AB, company reg. no. 556010-1155, with the address Box 507, 261 24 Landskrona, Sweden, as the ultimate parent company), (“we”, “us” or “our”), process personal data.

Privacy matters are important for us and your integrity is our priority. Therefore, it is important for us to protect your personal data and ensure that our processing of the data is conducted in a correct and lawful manner. In this privacy policy, we explain which types of personal data we may process about you and for what purpose we process them. We also detail our processing of personal data as well as what choices and rights you have in relation to such processing. We kindly ask you to carefully review our privacy policy and acquaint yourself with its content.

Please note that this privacy policy relates to processing of personal data for which a Haldex Group entity is the controller. This means that we are responsible for the processing of your personal data. It also means that you should turn to us with questions or remarks, or if you wish to enforce any of your rights in relation to our processing of your personal data. For any questions regarding our processing of your personal data, integrity or privacy, please contact us at privacy@haldex.com.

We may make additions or amendments to this privacy policy. If we do so, we will inform you by publishing the updated privacy policy on our website. In such case, we kindly ask you to carefully review the updated privacy policy.

In Appendix A, contact details to all Haldex Group entities are provided. Furthermore, any local deviations from what is stated in Haldex’s Privacy Policy due to local legislation are stated in Appendix A under the entity where the local deviation is applicable. Such deviations shall prevail over what is otherwise stated in Haldex’s Privacy Policy.

Generally, the Haldex Group entity that you enter into an agreement with, have contact with, visit or apply for a job with is the responsible data controller of your personal data. However, personal data is shared within the Haldex Group and, thus, other Haldex Group entities may also act as data controller with regards to your personal data. For example, personal data may be shared by a Haldex Group entity to another due to that the responsible key account manager is employed at the other Haldex Group entity. In such a case, the receiving Haldex Group entity is the responsible data controller of your personal data for the purpose of which the data was received.

Sharing of personal data within the Haldex Group is carried out for the purposes customer management, central administering of customer and supplier relationships, and for the purpose of streamlining Haldex’s business operations. The sharing of personal data is carried out on the basis of Haldex Group’s legitimate interest to administer its contractual relations within the Haldex Group and maintain an effective business structure.

The personal data and the purposes of our data processing

Contact persons and business contacts with customers to Haldex

We may process the following personal data attributable to you as a contact person or business contact at a customer to us: name, contact details (for example business address, phone number and e-mail address), title, function, company, nationality, language, bank details, customer registration number, signature, photo and video.

We process such personal data, save photos and videos, for the purposes of making sales, delivering goods, submitting offers, receiving payment, contacting you regarding business and sales, marketing and for being able to visit you as a customer. The processing is conducted on the basis of our legitimate interest to administer the contract with our customer and to be able to market and sell our products. Photos and video are processed when, for example, a Haldex Group entity organizes a seminar, marketing event or similar gatherings. Photos and video are taken where you as a participant may be visible. These photos and/or videos may be published on Haldex Group’s social media channels such as Facebook, LinkedIn, etc. This processing is conducted on the basis of Haldex Group’s legitimate interest of being able to communicate and promote such events for marketing and information purposes. If you do not wish to have your photo and/or video published you can talk to a Haldex representative at the event or contact us at privacy@haldex.com.

Contact persons with suppliers and service companies

We may process the following personal data attributable to you as a contact person at a supplier or service company to us: name, contact details (for example business address, phone number and e-mail address), company, title and function, supplier registration number, bank details, fax number, website and GPS tracking of your companies’ facilities.

We process such personal data for the purposes of processing and paying invoices, maintaining updated information for Haldex Select and on Haldex’s website, and contacts in regards to business and potential business with new suppliers. The processing is conducted on the basis of our legitimate interest to administer the contract with our supplier or a service company, to be able to streamline our business and contacts with service suppliers and service companies and to contact potential service suppliers and companies for future business opportunities, and to be able to provide customers with updated information regarding workshops and distributors.

Visitors at a Haldex Group entity’s premises

We may process the following personal data attributable to you as a visitor at a Haldex Group entity’s premises: name, company, name of host, agenda, vehicle registration number, date and time arriving and leaving the Haldex Group entity’s premises.

We process such personal data for the purposes of being able to keep a visitors log which can also be provided to the fire brigade in case of emergency, and to comply with health and safety obligations. The processing is conducted on the basis of the Haldex Group entity’s legitimate interest to be able to maintain security and a log of external visitors, as well as providing information to the fire brigade in case of emergency. Processing is also conducted on the basis of complying with applicable health and safety obligations.

Visitors on Haldex’s website

We may process the following personal data attributable to you as a visitor on Haldex’s website: cookies, location, IP-address and used language.

We process such personal data for the purposes of tracking website statistics and gather information about your preferences when navigating the website in order for us to provide you with relevant information. Haldex uses cookies, including third-party cookies, to gather visitor statistics and information about your preferences when visiting Haldex’s website in order for us to provide you with relevant information. Cookies are small text files that the website you are visiting asks to save on your receiver device, for example your computer. If you do not want to accept the use of cookies, you can change your web browser settings to automatically deny the storage of cookies or to inform you each time a website requests permission to store a cookie. By choosing not to accept cookies, the Haldex website may not function as intended. The processing is conducted on the basis of our legitimate interest to gather, monitor and analyze website activity. You do, however, also have to agree with the processing of cookies as set out in the cookie banner which appears when you enter the website.

We may process the following personal data attributable to you as a visitor who registers on Haldex’s website: name, contact details (for example business address, phone number and e-mail address), nationality and company.

We process such personal data for the purpose of enabling customers to place order and view invoices online. The processing is conducted on the basis of Haldex Group’s legitimate interest of enabling customers to place and administer orders online.

Job applicants

We may process the following personal data attributable to you as a candidate in a recruiting process: name, contact details (for example phone number and e-mail address), personal identity number/social security number, CV, assessments by recruiters and analysis results.

We process such personal data for the purposes of assessing candidates that have applied for a job with a Haldex Group entity and for the candidate to be able to carry out a personality test online. The processing is conducted on the basis of our legitimate interest of being able to assess candidates prior to a potential employment. Your personal identity number/social security number is processed because it’s clearly motivated on the basis that we need to ensure your identity.

Storage of personal data

We store your personal data as long as necessary for us to fulfil the purpose of the processing. Below, specific retention times are set out for each category of persons.If your personal data is no longer essential in order for us to fulfil the purpose of the processing, or if the processing for any other reason is no longer allowed, the data will be anonymized or deleted.

Contact persons and business contacts with customers and service suppliers

If our relationship with your company ends, or if we are informed that you no longer hold the position as contact person, your personal data will be deleted within six months. However, personal data held for marketing purposes may be processed until you object to such processing.

In certain cases we may store your personal data for longer than the six months stated above, for example if we are required by law to store certain data for accounting records purposes or other legal requirements. Furthermore, your personal data may be stored for a longer period of time if it is necessary to process the data to settle commercial disputes following a terminated contractual relationship between us and the company you work for. In these cases, your personal data will be deleted immediately when the data is no longer necessary for the purposes they were stored.

Visitors at a Haldex Group entity’s premises

After your visit, your personal data will be deleted within three months.

Visitors on Haldex’s website

Cookies are removed in accordance with the cookie policy. We will store personal data relating to a registered visitor for as long as you have an active account. When your account is deactivated, your personal data will be deleted within three months.

Job applicants

After the recruiting process is finalized, your personal data will be deleted within three months. With your consent, we may store your personal data for a longer period of time for the purpose of future recruitments and job opportunities. If you consent, we may therefore store your personal data for two years as of when you applied for a job with a Haldex Group entity.

Recipients of personal data

We may disclose your personal data to our data processors, for example companies providing IT- and cloud services. In such cases, data processing agreements are entered into to ensure that your personal data is processed in a manner consistent with this privacy policy.

As stated above, the Haldex Group entities may also share your personal data internally within the Haldex Group. Furthermore, your personal data may be shared with third parties, including authorities, customers and suppliers, only for the purposes set out above. You are referred to such third parties’ privacy policies for information about their processing of your personal data in their capacity as data controller.

Your rights

You have the right to receive confirmation on whether or not we process personal data concerning you, and in such cases get access to such personal data and information regarding the personal data and how we process it.

You have the right to have inaccurate personal data concerning you rectified without undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete personal data about you completed.

You have, under certain circumstances, the right to have personal data concerning you erased, for example, if the personal data is no longer necessary in relation to the purposes for which they were collected or if the personal data have been unlawfully processed.

If our processing is based on your consent, you can withdraw the consent by contacting us. If you do, we will no longer conduct such processing.

In some circumstances you have the right to obtain restriction of the processing of your personal data. For example, if you contest the accuracy of the personal data, you can also require that we restrict the processing of your personal data for such a period that enables us to verify the accuracy of the personal data.

You have the right to object to processing of your personal data that is based on our legitimate interests. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal data.

You have the right to receive the personal data relating to you and that you have provided to us, in a commonly used electronic format. You have the right to transmit that data to another controller such as another company or organization (data portability).

If you have any questions or comments relating to our processing of your personal data, you are welcome to contact us at privacy@haldex.com. You have the right to complain on the processing of your personal data by lodging a complaint to the applicable Data Protection Authority.