Privacy Note for VASD - Vectron Advanced Service Documentation App
Last update: Jan 22nd, 2022
Protecting the security and privacy of your personal data is important to Siemens Mobility GmbH, Otto-Hahn-Ring, 81739 Munich, Germany (“Siemens”). Therefore, Siemens operates the VASD - Vectron Advanced Service Documentation (“App”) in compliance with applicable laws on data protection and data security.
Categories of personal data processed, purpose of the processing and legal basis
When visiting and using the VASD, Siemens processes the following personal data about you:
- Name, including first or last name,
- Email Address, including but not limited to a hashed email address,
- Phone Number, including but not limited to a hashed phone number,
- User ID such as screen name, handle, account ID, assigned user ID, customer number, probabilistic identifier, or other user- or account-level ID that can be used to identify a particular user or account
- Device ID such as the device’s advertising identifier, or other device-level ID.
- Crash Data such as crash logs,
- Performance Data such as launch time, hang rate, or energy use,
We process your personal data for the following purposes:
- Analytics, meaning using data to evaluate user behavior, including to understand the effectiveness of existing product features, plan new features, or measure audience size or characteristics,
- VASD Functionality
- Operation of the VASD, such as to authenticate the user, enable features,
- Maintenance and Support, such as ensure server up-time, minimize app crashes, improve scalability and performance, or perform customer support,
- Security, such as prevent fraud, implement security measures,
We only process your personal data if we are permitted by applicable law to do so. In particular, if you are based in the European Economic Area, the legal basis for Siemens processing data about you is that such processing is necessary for the purposes of:
- Siemens exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
- Compliance with Siemens’ legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or Legitimate interests pursued by Siemens (Article 6 (1) (f) General Data Protection Regulation).
Generally, the legitimate interest pursued by Siemens in relation to our use of your personal data is the efficient operation, management and support of the VASD, but we may disclose other legitimate interests for specific uses.
Where we rely on our legitimate interests for a given purpose, we are of the opinion that this legitimate interests is not overridden by your interests and rights or freedoms, given
- (i) the regular reviews and related documentation of the processing activities described herein,
- (ii) the protection of your personal data by our data privacy processes, including our Binding Corporate Rules on the Protection of Personal Data,
- (iii) the transparency we provide on the processing activity, and
- (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact our Data Privacy Organization at: firstname.lastname@example.org.
In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for Siemens processing that personal data is that you have consented (Article 6 (1) (a) General Data Protection Regulation).
Transfer and disclosure of personal data
For the purposes mentioned above Siemens may transfer or disclose your personal data to:
- other affiliated companies or third parties - e.g. sales partners or suppliers - in connection with your use of the Online Offerings or our business relationship with you;
- third parties which provide IT services to us and which process such data only for the purpose of such services (e.g., hosting or IT maintenance and support services); and
- third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to law enforcement authorities and regulators, to attorneys and consultants).
If you are located within European Economic Area, please be aware that sometimes the recipients to whom Siemens transfers or discloses your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country.
In such cases and if required by applicable law, Siemens takes measures to implement appropriate and suitable safeguards for the protection of your personal data. In particular:
- We share your personal data with Siemens companies in such countries only if they have implemented the Siemens Binding Corporate Rules („BCR“) for the protection of personal data. Further information about the Siemens BCR can be found here.
- We transfer personal data to external recipients in such countries only if the recipient has (i) entered into EU Standard Contractual Clauses with Siemens, (ii) implemented Binding Corporate Rules in its organization. You may request further information about the safeguards implemented in relation to specific transfers by contacting email@example.com.
Unless explicitly indicated otherwise at the time of the collection of personal data (e.g. within a consent form accepted by you), we erase personal data if the retention of the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed and no statutory retention obligations under applicable law (such as tax or commercial law) require us to further retain personal data.
The data protection law applicable to Siemens when processing your personal data may entitle you to specific rights in relation to your personal data. You can find out more about those rights by contacting firstname.lastname@example.org.
In particular and subject to the respective statutory requirements, if you are located in the European Economic Area, you are entitled to:
- Obtain from Siemens confirmation as to whether or not personal data concerning you are being processed, and where that is the case, access to the personal data;
- Obtain from Siemens the rectification of inaccurate personal data concerning you;
- Obtain from Siemens the erasure of your personal data;
- Obtain from Siemens restriction of processing regarding your personal data;
- Data portability concerning personal data, which you actively provided; and
- Object, on grounds relating to your particular situation, to processing of personal data concerning you.
Data Privacy Contact
The Siemens Data Privacy Officer and his team (the “Siemens Data Protection Organization”) provide support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights.
The Siemens Data Privacy Organization may be contacted at: email@example.com.
The Siemens Data Privacy Organization will always use best efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the Siemens Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.
Do Not Track
At this time our Internet sites do not recognize or respond to “Do Not Track” browser signals.
The VASD is not directed to children under the age of thirteen. We will not knowingly collect personal data via this Application from children under the age of thirteen without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.
To protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, Siemens uses reasonable physical, technical and organizational security measures. Unfortunately, there is no complete assurance of security in transit or storage to any information that you transmit, no complete assurance that information will not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or organizational measures.
For US Residents only
There are special notices that may need to be given to, and rights that may be available to, residents of certain US states. Please click here for those notices.
Siemens publishes privacy notices for selected mobile applications, including VASD - Vectron Advanced Service Documentation App here: https://new.siemens.com/global/en/general/legal/app-privacy-notices.html
We may update this Privacy Notice from time to time.