This is an important notice regarding your privacy and the way in which Andreas Stihl Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to our applicants, business contacts (i.e. clients and prospective clients), contractors, approved dealers, journalists, suppliers, customers and competition entrants generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of applicable privacy legislation, the data controller is Andreas Stihl Limited of Stihl House, Stanhope Road, Camberley, Surrey, United Kingdom, GU15 3YT. Our company registration number is 01376302.
Questions regarding this policy should be directed to our Data Protection Officer. The Data Protection Officer is responsible for ensuring compliance with relevant data protection legislation and with this policy. That post is held by our Company Secretary, who can be contacted at firstname.lastname@example.org. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer.
1. What information do we hold about you?
• Personal contact details such as your name, title, address, telephone number, and e-mail address.
• Recruitment information (including personal information such as copies of your right to work documents, your CV or cover letter which is sent to us as part of the application process).
• Information provided to us by recruitment agencies in relation to your application for employment with us.
• Information collected during the course of your application including psychometric and personal profiling data (i.e. tests administered by our third party test supplier).
• Contact details such as your name, title, business telephone number and business e-mail address.
• Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
• Bank details of individual sole traders.
• Other personal information you provide to us via our website, for example, by using the “How to contact us” page.
• Personal contact details such as your name, title, address, telephone number, e-mail address, photo (if you provide one) and details of your next of kin (if required).
• Travel documentation (if you provide these documents) including passport details.
• Personal contact details such as your name, address, telephone number and e-mail address.
• Personal information contained on your social media accounts, for example, Facebook or Twitter.
• Payment information such as credit/ debit card number, expiration date, security code and name as it appears on the card and the address the card is registered to.
• Details which you provide to us or our approved dealers in connection with product warranty registration.
• Other personal information provided to us via our website or social media accounts, for example, by using the “Contact Us” page on our website or by contacting us on Facebook or Twitter.
• Personal information provided to us by the third party service providers we work with, for example, analytics providers and third party companies providing us with marketing assistance.
Contractors and Suppliers
• Personal details such as your name, address, bank account information and telephone number.
• If you enter or apply to enter any of our competitions or events, for example STIHL® TIMBERSPORTS® SERIES, personal information including your name, e-mail address, telephone number, bank details (if relevant), any health related information you give to us and photos and/or videos of you.
• Where you enter into the STIHL® TIMBERSPORTS® SERIES, we will publish any competition records on our STIHL® TIMBERSPORTS® SERIES website.
• If you visit our offices, images and videos are recorded by the CCTV system in operation on our premises.
• Information gathered when you visit our offices via our visitor sign-in process, including your name.
• If you visit our offices and login to our guest Wi-Fi network, information may be collected about your usage.
• Any personal information you provide to us during your interactions with us.
• Photos and/or videos of you which may be taken at one of our events, in connection with one of our promotions or any other way.
• Information provided to us by third party service providers we work with, for example, payment service or analytics providers.
2. How will we use your personal information and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
• Where you have provided us with your consent for us to do so;
• Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you;
• Where we need to comply with a legal obligation to which we are subject;
• Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:
• To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
• To carry out right to work checks – to comply with a legal obligation.
• To carry out driving licence checks – in pursuit of our legitimate interests to verify your suitability for our driver vacancies.
• Dealing with your enquiry made via the “Contact Us” page on our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
• Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information – in pursuit of our legitimate interests in keeping you informed about our products, services and business updates.
• Your personal contact details – in pursuit of our legitimate interests (to facilitate business between you or your business and us).
• Your travel documentation – in pursuit of our legitimate interests in facilitating approved dealer trips.
• Your personal details to provide training to you and record training provided by us – in pursuit of our legitimate interests in demonstrating that we have fulfilled our training commitment to you.
• Your exam results from the training course – in pursuit of our legitimate interest to accurately keep records of your training with us.
• Your next of kin information – in pursuit of our legitimate interests (to contact in the event of an emergency).
• Providing you with information about the products you have purchased from our approved dealers – to perform the contract with you.
• Dealing with your enquiry made via the “Contact Us” page on our website or social media – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
• Your contact details to provide you with information on our products and services. This may include marketing information – where you have provided us with your consent for us to do so.
Contractors and Suppliers
• Your personal details – in pursuit of our legitimate interests (to facilitate business between you and us).
• Your personal details provided to us in connection with the competition or event that you have applied to enter into – in pursuit of our legitimate interests in effectively managing the competition you have entered into.
• Images of you captured by photo and/or video – where you have provided us with your consent for us to do so.
• Any personal information you provide to us relating to your health or dietary requirements – where you have provided us with your explicit consent for us to do so.
• Your STIHL® TIMBERSPORTS® SERIES competition records on our website – in pursuit of our legitimate interest in publicising the competition records.
• To ensure our premises are kept secure – in pursuit of our legitimate interests (in ensuring our premises are kept secure and to keep evidence of this).
• Health and safety purposes – to comply with a legal obligation.
• To track your Wi-Fi usage – in pursuit of our legitimate interests (in ensuring our network is being used for acceptable purposes).
• Images of you captured by photo and/or video – where you have provided us with your consent for us to do so.
• To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
• To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
• To transfer to third party service providers – in pursuit of our legitimate interests (in outsourcing for effectiveness and efficiency).
• To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
3. What happens if there is a change of purpose?
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4. Which type of third parties might we share your personal information with?
We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
We may share your personal information with the following types of third parties:
• Technical support providers, for example, assisting with our website.
• Recruitment agencies assisting us with filling our vacancies.
• Professional advisers such as lawyers, accountants, insurance companies and business analysts.
• Providers assisting us with the management of our competitions.
• Providers which help us collate and organise information effectively and securely.
• Providers which help us generate and collate surveys and reviews of our products and services.
• Providers which assist us with marketing by, for example, helping us send marketing mailshots and providing catalogues where requested.
• Providers which help us with logistics and delivery solutions.
• Third party software hosting companies which provide us with software solutions.
• Providers which host our servers in their data centres (these are all within the UK and Germany).
• Providers which help us book and manage our trips such as airlines, hotels and travel agents.
5. Data retention
How long will we use your personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
• Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
• Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months.
The period we keep your personal information depends on a number of circumstances. For example:
• Where we have collected your personal information during the course of your and our organisations doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
• We will keep your bank account details for as long as we do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
• Where you have provided us with your personal information during the course of making a complaint, we will keep this information for 6 years.
• We will keep your passport and next of kin details for the duration of the approved dealer trip and delete thereafter.
• We will keep your training records and exam results for the period during which that certificate or training remains valid.
• If you have consented to receiving marketing information, we will keep your personal information for as long as we still have your consent;
• If you have provided us with your personal information for the purpose of making a complaint, we will keep this information for 6 years.
Contractors and Suppliers
• We will keep your personal information for as long as we and you do business together or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
• Except for competition records, we will keep your personal information for a period of 6 years after a competition.
• Any data collected through our visitor sign-in system is stored for 10 days only.
• Any data collected through our CCTV system is stored for 31 days only.
6. Where we store your personal data
Electronic versions of your personal information are stored on our servers in the UK and Germany.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
Where your data is transferred outside of the EEA, we will take steps to ensure your personal information is adequately protected.
7. Rights of access, correction, erasure and restriction
Your rights in connection with your personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request the erasure of your personal information. This enables you to ask us to delete or remove personal information when there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
8. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access any personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
10. Right to withdraw consent
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
11. What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our premises).
12. Right to complain
You have the right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (email@example.com).
13. Changes to this privacy notice
We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.