Siemens Data Privacy Notice

January 2019

 

Protecting the security and privacy of your personal data is important to Siemens. Therefore, Siemens (for further company details, please see the “Corporate Information” below) processes personal data 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 Siemens’ websites, applications or online tools (each a “Siemens Online Offering”), Siemens may process the following personal data about you:

  • Personal data that you actively and voluntarily provide via the Siemens Online Offering (e.g., when registering, contacting us with your inquiries or participating in surveys, etc.), including name, e-mail address, telephone number, information submitted as part of a support request, comments or forum posts, etc.; and
  • Information that is automatically sent to us by your web browser or device, such as your IP-address, device type, browser type, referring site, sites accessed during your visit, the date and time of each visitor request.

We process your personal data for the following purposes: 

  • To provide the Siemens Online Offering’s services and functions and to administer your use of the Siemens Online Offering;
  • To verify your identity (if you registered for a Siemens Online Offering);
  • To answer and fulfill your specific requests; 
  • To send you marketing information or to contact you in the context of customer satisfaction surveys as further explained in Section 3; and
  • As reasonably necessary to enforce the applicable terms of use, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on Siemens’ information technology systems.
  • If you are an existing customer of Siemens Financial Services Ltd., (or are applying to become a customer of Siemens Financial Services Ltd.), please click here to understand how we process your information.

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 performance or management of your use of the Siemens Online Offerings.

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 data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

 

Cookies

 

We may use cookies within Siemens Online Offerings. You can find information on Siemens’ use of cookies in our Cookie Policy. The Cookie Policy also provides information on how to block and object to the use of cookies and the processing of data collected by cookies.

 

Google Maps

 

In order to offer you certain location-based functions, some Siemens Online Offerings may use “Google Maps” (e.g. to let you obtain directions to your local Siemens point of contact). When you use Google Maps, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“) will process personal data which may include, inter alia, your device’s IP address and your location. Location data can only be processed if you granted permission to access, or actively provided your location data within the relevant Siemens Online Offering.

The data controller responsible for the processing of your personal data in connection with Google Maps is Google; Google’s privacy notice can be found at https://www.google.com/policies/privacy.

 

Links to other websites

 

This Privacy Notice applies only to Siemens Online Offerings and not to other websites or applications operated by third parties. We may provide links to other websites and applications which we believe may be of interest to you. Siemens is not responsible for the privacy practices of such other websites or applications.

 

Mobile Applications

 

Some applications of Siemens that you can download to your mobile device (“Mobile Apps”) have their own Privacy Notices. These Privacy Notices are made available to you in the respective App Store before you download the Mobile App and within the respective Mobile Application itself. The Privacy Notices of selected Siemens’ Mobile Apps are also published here.

Categories of personal data processed, purpose of the processing and legal basis

 

In the context of the business relationship with Siemens, Siemens may process the following categories of personal data of  contact persons at (prospective) customers, suppliers, vendors and partners (each a “Business Partner”): 

  • Contact information, such as full name, work address, work telephone number, work mobile phone number, work fax number and work email address; 
  • Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information; 
  • Further information necessarily processed in a project or contractual relationship with Siemens or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones; 
  • Personal data collected from publicly available resources, integrity data bases and credit agencies; and
  • If legally required for Business Partner compliance screenings: date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners.

Siemens may process the personal data for the following purposes: 

  • Communicating with Business Partners about products, services and projects of Siemens or Business Partners, e.g. by responding to inquiries or requests or providing you with technical information about purchased products;
  • Planning, performing and managing the (contractual) relationship with Business Partners; e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
  • Administrating and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests, or other promotional activities or events;
  • Conducting customer satisfaction surveys and direct marketing activities as further explained in Section 3; 
  • Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities; 
  • Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and Siemens policies or industry standards; and
  • Solving disputes, enforce our contractual agreements and to establish, exercise or defend legal claims.

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 performance or management of our business relationship with you.

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 data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

Where and as permitted under applicable law, Siemens may process your contact information for direct marketing purposes (e.g. trade show invitations, newsletters) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these  purposes at any time by writing to contact@siemens.com or by using the opt-out mechanism provided in the respective communication you received.

Siemens may transfer your personal data to:

  • other Siemens companies or third parties  - e.g. sales partners or suppliers - in connection with your use of the Siemens Online Offerings or our business relationship with you;
  • third parties which provide IT services to Siemens and which process such data only for the purpose of such services (e.g., hosting or IT maintenance and support services); and/or
  • 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).

Sometimes the recipients to whom Siemens transfers 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, 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 or (iii) – in case of US recipients – the recipient is certified under the Privacy Shield. You may request further information about the safeguards implemented in relation to specific transfers by contacting dataprotection@siemens.com.

Personal data published by you on Siemens Online Offerings (such as chat rooms or forums) may be globally accessible to other registered user of the respective Siemens Online Offering. 

Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary (i) for the purposes for which they were collected or otherwise processed, or (ii) to comply with legal obligations (such as retention obligations under tax or commercial laws).

In case you declared your consent for the processing of certain personal data by Siemens, you have the right to withdraw the consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If the consent is withdrawn, Siemens may only further process the personal data where there is another legal ground for the processing. 

Under applicable data protection law you may have the right 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.

Further background information and explanations related to the rights described above are available on the European Commissions’ website “Rights for citizens”.

The Siemens Data Protection Organization provides 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: dataprotection@siemens.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. 

 

A list and contact details of local data protection authorities is available here.