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Version 1 of 25.10.2024
Effective from 5 Nov, 2024
Market: European Market
At Hero MotoCorp Ltd. (“Hero MotoCorp”, “we”, “us”) protecting your privacy and your personal data is a top priority. In this Privacy Notice you will find information on how we process your personal data, the purposes for which your personal data is processed, and the data subject rights you have in this regard.
Should you require additional information beyond what is presented in this Privacy Notice, please do not hesitate to reach out to us using the contact details listed in Section 1 of this Privacy Notice.
PRIVACY NOTICE SCOPE
In this Privacy Notice we provide you with information in accordance with the requirements of the European General Data Protection Regulation (“GDPR”, Regulation (EU) 2016/679 of the European Parliament and of the Council). We also observe the requirements of other national data protection legislation that may apply to the processing of your personal data.
This Privacy Notice contains information on the processing of your personal data (and in addition to the relevant processing as set out below) in relation to our website, with regard to you as a customer and user of Hero MotoCorp products and services, and with regard to you as a business partner as follows:
- Controller and data protection officer
- General information on the processing of your personal data
- Processing of your personal data in relation to our website
- Processing of your personal data with regard to you as a customer and user of Hero MotoCorp products and services
- Processing of your personal data with regard to you as a business partner
- Storage period
- Recipients of your personal data
- Transfer of your personal data to countries outside the European Economic Area
- Your rights and asserting
- Changes to this Privacy Notice
1 CONTROLLER AND DATA PROTECTION OFFICER
1.1 Controller
The controller under data protection law decides on the purposes and means of processing your personal data and ensures compliance with the data protection regulations. If multiple controllers decide together the purposes and means of processing, these controllers are jointly responsible for the processing, which is referred to joint controllership.
The following controller processes your personal data:
[Hero MotoCorp Limited]
Postal address: The Grand Plaza, Plot No.2, Nelson Mandela Road. Vasant Kunj – Phase -II, New Delhi – 110070
Telephone: +91-11-46044200
We may also share your personal data with companies who are part of the Hero MotoCorp Group, and other third parties. These companies may process your personal data either as independent controllers, joint controllers or as our processors.
1.2 Data protection office
You can contact our data protection office if you have any questions about the processing of your personal data by us and other Hero MotoCorp Group companies, acting as joint controllers with us: [email protected]
GENERAL INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA
1.3 Processing of your personal data
When we use the term “personal data” in this Privacy Notice, we mean all information that relates to you.
Personal data includes, for example, your name, email address or postal address. Your personal data also includes all data that is linked or relates to you. Data that does not relate to you we shall refer to as non-personal or anonymous data. The data protection regulations and this Privacy Notice do not apply to such data.
For example, by processing your personal data, we mean its collection, storage or erasure.
1.4 Legal basis for processing (overview)
We process your personal data only if we can base the processing on a legal basis or if such is lawful in accordance with the applicable data protection regulations, i.e. that the processing is permissible within the scope of the law. In the context of the GDPR, we base the processing of your personal data for the most part on the following legal bases:
- The processing of your personal data is necessary for the fulfilment of a contract with you or for the implementation of pre-contractual measures that take place at your request (Article 6 (1) (b) GDPR).
- You have given us your clear consent to the processing of your personal data for one or more specific purposes (Article 6 (1) (a) GDPR).
- The processing of your personal data is necessary to fulfil a legal obligation (Article 6 (1) (c) GDPR).
- The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of your personal data (Article 6 (1) (f) GDPR).
Further information on the processing we undertake and the relevant lawful basis on which we process your personal data, can be found below in this Privacy Notice.
1.5 Personal data we process
We process personal data that you provide to us, that we collect (automatically) or that we receive from third parties.
You are not obligated to provide us with your personal data. However, the processing of certain personal data may be necessary, e.g. to enable us to offer and provide our website or to perform contracts concluded with you as a customer or business partner.
Personal data you provide to us
We process the personal data you provide to us. For example, when you call or contact us and provide us with certain personal data in this way. In relation to our website, you can provide us with further personal data when you select certain settings or configure a solution according to your needs. We collect and process this data to enable you to use our website. If you do not provide us with certain information, the use or functionality of our website may in part stop or be impaired.
Purpose
- To facilitate or fulfil the information, products or services You have requested;
- To contact the User for confirming Your registration on our Sites / Apps;
- To communicate with the User to respond to his/her queries or seeking feedback or resolving disputes on the product and services;
- For business, marketing and promotional purposes such as sending information about special promotions, programs, schemes, offers, new features, plans on products/services & marketing communications that we believe may be of interest to You;
- To educate You about us, our products and services or to understand Your interest to improvise the content and performance of our Sites/Apps;
- To send You important information regarding the Sites/Apps, changes in terms and conditions, user agreements, and policies and/or other administrative information;
- For internal business operations including:
- Reviews and data analysis for the website (e.g., to determine the number, category of visitors to specific pages within the Sites/Apps);
- To manage, operate, maintain and secure our Sites/Apps, network system and other assets and to customize/personalize Your experience with us, which may include displaying content based upon Your preferences;
- For the purposes of analyzing the use of the Sites/Apps, enabling and monitoring Your use of our Sites, /Apps operating our Sites/Apps, ensuring the security of our Sites/Apps, for maintaining back-ups of our databases;
- To help diagnose problems with our server, and to administer our Sites/Apps.
- To comply with our legal obligations or as otherwise permitted by law.
- To investigate potential breaches, or to protect the rights, property or safety of Hero, the Users of our Sites/Apps or others.
- For any other purpose necessary or incidental to our business.
- For any other purpose for which You give Your consent.
- To enforce our terms and conditions;
- For information provided in relation to Platform Services:
- To generate/refine offers for loans as accessible on the Sites/ Apps;
- To provide customized recommendations and personalized offers of the products and services of Hero and/or its business partners/affiliates;
- To send information/personalized offers via email, text, call or online display or other means of delivery in Hero’s reasonable sole discretion;
- For marketing survey, customer research, feedback and internal administrative purposes subject to applicable laws;
- For compliance with legal and regulatory obligations;
- To provide You with customized recommendations and personalized/ pre-approved offers of loans from Financiers which may be available if You purchase a Hero vehicle;
- To send You information / personalized offers via email, text, call or online display or other modes/channels at the sole discretion of Hero;
- To improve customer experience on the Sites/ Apps
Personal data we collect
In relation to our website, we collect certain personal data automatically and process it when you visit our website. This includes, for example, data such as your IP address, certain login data and data that will be processed so that we can technically provide you with our website.
Personal data that we receive from third parties
In some cases, we receive your personal data from indirect sources – i.e. not directly from you. This may be the case, for example, if personal data about you is provided to us by third parties. We work with companies that provide services to us and who in turn provide us with personal data about you.
2 PROCESSING OF YOUR PERSONAL DATA IN RELATION TO OUR WEBSITE
In relation to our website, we will inform you about the processing of your personal data relating to the web addresses (Uniform Resource Locator, “URL”) you access.
2.1 Visiting the Hero MotoCorp website
When accessing our website, the browser used on your device automatically sends information to the server of our website and temporarily saves it in a ‘log file’.
If you would like to be informed about the cookies used by us on our website, you can find more information here.
Categories of personal data
The following information will be processed when the website is accessed:
- The IP address of the requesting internet-enabled device;
- Other device details, such as language settings;
- The date and time of access;
- The name and URL of the retrieved file;
- The website/application from which access was made (referrer URL); and
- The browser you are using and, if applicable, the operating system of your Internet-enabled computer and the name of your access provider.
Purpose
The processing of your personal data serves the following purposes:
- Ensuring a smooth connection and functioning of our website;
- Improving the content of our website;
- Providing you with more personalized and improved user experience;
- Ensuring a comfortable use of our website; and
- Evaluating system security and stability.
Legal basis
We base the processing of your personal data on the following legal bases:
- The website is accessed during the initiation or execution of a contract.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- The processing of your personal data is necessary to enable you to access the website and to ensure the performance, consistent functionality and security of our website and systems.
It is in our legitimate interest to ensure the performance, consistent functionality and security of our website and systems.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
2.2 Register your Hero MotoCorp account on our website
There are offerings and services on our website that require a Hero MotoCorp account. The Hero MotoCorp account is your user account with which you log in after registration with our website.
As part of the registration process, we will inform you which information is required for registration and which is voluntary.
Categories of personal data
The following information is processed when registering a Hero MotoCorp account:
- First name, surname, title, email address, date of birth;
- Contact and address data;
- Your country and language;
- Password;
- Date and time of registration; and
- The version of the terms of use that you accept and the date and time of your consent.
Purpose
The processing of your personal data serves the following purpose:
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- Setting up and providing a Hero MotoCorp account as a user account to use the offerings and services on our website that require a Hero MotoCorp account.
Legal basis
We base the processing of your personal data on the following legal bases:
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- The processing of your personal data is necessary for setting up your Hero MotoCorp account and making it permanently available to you as your user account for our website.
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We process your personal data based on Article 6 (1) (b) of the GDPR.
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- The processing of your personal data, which is not necessary to create and to provide you with your Hero MotoCorp account and which you voluntarily provide to us is carried out to enable us to, for example, improve your experience with Hero MotoCorp:
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We process your personal data based on Article 6 (1) (f) of the GDPR.
It is in our legitimate interest to improve your usage experience of our website and to provide you with a user account.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
2.3 Logging in with your Hero MotoCorp account with our website
You use your Hero MotoCorp account to log in on our website.
Categories of personal data
The following information will be processed when logging in with the Hero MotoCorp account:
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- Your Hero MotoCorp account; and
- The password you have set for your Hero MotoCorp account.
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Purpose
The processing of your personal data serves the following purposes:
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- Logging in and authentication with our website;
- Access to the data stored by you with our website; and
- Protecting your account and data from unauthorized access.
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Legal basis
We base the processing of your personal data on the following legal basis:
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- The processing of your personal data is necessary for enabling you to log in on our website.
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We process your personal data based on Article 6 (1) (b) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
2.4 Newsletter
On our website we give you the opportunity to register for our newsletter.
Please note that we use the so-called double opt-in procedure to ensure that you want to receive our newsletters. After you sign up for the newsletter, we will send you a confirmation link to the email address you have provided. Only when you confirm your email address and interest in receiving our newsletter will we include you in our email distribution list.
Please note that when sending the newsletter, we carry out performance measurement and analyze your usage behavior. For this analysis the emails sent contain so-called web beacons or tracking pixels. These are located on our servers and tell us when and how you retrieve our newsletter. For the analysis we link the above-mentioned data and web beacons to your email address.
You can disable the display of images by default in your email application to restrict the processing of data through the use of our newsletter. In this case you will not be able to see the newsletter in full and you may not be able to use all the features. If you have the images displayed manually, the above-mentioned tracking is performed.
Categories of personal data
The following information is processed in connection with the newsletter distribution:
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- Information such as the opening rate, when you read our newsletters and what links you click on in the newsletter; and
- Information that we collect about you when you use our services (e.g. when purchasing our products).
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Purpose
The processing of your personal data serves the following purpose:
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- We infer your interests from the processing of your personal data in order to be able to provide you with a version of our newsletter that is tailored to suit your interests and that contains information on the products and services that are relevant to you.
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Legal basis
We base the processing of your personal data on the following legal basis:
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- Your personal data are processed based on your consent given when you subscribe to our newsletter.
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We process your personal data based on Article 6 (1) (a) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve this purpose. WWe will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
2.5 Completion of surveys
On our website, we may ask you to complete surveys. These surveys are used to gather feedback on our services and products and on your user experience when visiting our website. Participation in such surveys is voluntary.
Categories of personal data
The following information is processed in connection with the completion of surveys:
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- Your IP address; and
- Your answers to the questions in the survey.
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Purpose
The processing of your personal data serves the following purposes:
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- Analyzing satisfaction with our products and services and improving our products and services; and
- Analyzing user satisfaction and improving the user experience when visiting our website.
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Legal basis
We base the processing of your personal data on the following legal basis:
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- Your personal data are processed based on your consent given when you participate in the survey.
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We process your personal data based on Article 6 (1) (a) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
3 PROCESSING OF YOUR PERSONAL DATA WITH REGARD TO YOU AS A CUSTOMER AND USER OF HERO MOTOCORP PRODUCTS AND SERVICES
3.1 Support and communication with Hero MotoCorp
If you have any questions, you may contact us at any time by email, post, telephone, via contact forms or by other means. We shall usually respond to you through the medium through which you initiated contact.
Should you subscribe to our newsletter, then we shall provide you with further information regarding the processing of your personal data in relation to this subscription.
Categories of personal data
The following information will be processed when communicating with you:
- Your contact details such as telephone number or email address;
- Any personal data as part of communicating with you, including, where applicable, telephone conversations with you;
- Data relating to your request or concerns, such as the subject of your request or our communication with you; and
- The data necessary to clarify your request.
Purpose
The processing of your personal data serves the following purposes:
- Communicating with you when you have raised questions or other concerns;
- Handling and responding to your enquiries and concerns;
- Communicating with you outside of enquiries and concerns, for example, for information purposes or for the fulfilment of legal or contractual obligations; and
- Should we record telephone calls, this is done for quality assurance and training purposes and improving our support and only after we have obtained your consent.
Legal basis
>We base the processing of your personal data on the following legal bases:
- Processing your personal data in connection with our support is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- We provide you with certain support services outside of an existing contract.
We process your personal data based on Article 6 (1) (f) of the GDPR.
We have a legitimate interest in helping you in the event of questions about our offers and services and in ensuring the satisfaction of our (former and future) customers and users of our offers and services.
- For some processing of your personal data we shall obtain your consent where necessary in accordance with Article 6 (1) (a) of the GDPR.
This applies in particular to the recording of telephone calls.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
3.2 Visiting stores and communication with our sales officer at dealers and distributors
We are collaborating with third parties that are operating stores where you can explore and purchase our products. When you visit these stores or purchase our products in these stores, your personal data may be collected and shared with us by the third parties that are operating the stores. You may also contact our sales officer at dealers and distributors for any enquiries. The data will be processed by us, in particular for marketing or analysis purposes and to contact to support you with your enquiry.
Categories of personal data
The following information may be processed in connection with your visit of third-party stores:
- Your name;
- Your contact details such as telephone number or email address;
- Other information such as age;
- Information about the products and services that you are interested in or that you have purchased;
- Data relating to your enquiry;
- The data necessary to clarify your enquiry; and
- (If applicable) Date and place of purchase.
Purpose
The processing of your personal data serves the following purpose:
- Analysing the market and targeting groups for our products;
- Handling and responding to your enquiries and concerns; and
- Providing you with further information on products and services you are interested in and/or to support you with your purchase.
Legal basis
We base the processing of your personal data on the following legal basis:
- Processing your personal data in connection with your interaction when visiting a store or your communication with a sales officer and us.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- We have a legitimate interest in analysing the market and target groups for our products in order to develop our products and marketing strategy.
We process your personal data based on Article 6 (1) (f) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
3.3 Purchase of products and services
We offer our customers a range of products and services. When you purchase products or services from us, various personal data is processed in relation to the purchase process.
Categories of personal data
The following information will be processed when purchasing our products and services:
- Your name;
- Your contact details such as telephone number or email address;
- Other official identifiers (e.g. [TBD] );
- Banking information;
- Result of a credit check; and
- Know your customer (KYC) details.
Purpose
The processing of your personal data serves the following purposes:
- Performing the contract concluded with you; and
- Checking your solvency.
Legal basis
We base the processing of your personal data on the following legal bases:
- Processing your name, contact details (such as telephone number or email address), banking information and other official identifiers is necessary for the performance of the contract with you.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- We have a legitimate interest in ensuring your solvency to avoid the risk of non-payment and possible insolvency.
We process your personal data based on Article 6 (1) (f) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
3.4 Regulatory Obligations
We are subject to various regulatory obligations that may require us to process your personal data. An example of such an obligation is to inform you, as a customer, if you have purchased a product from us that cannot be used safely due to a production error.
Categories of personal data
The following information will be processed in order to comply with regulatory obligations:
- Your name;
- Your contact details such as telephone number or email address;
- Product/service details (type of the product/service, date of purchase); and
- Other information required to comply with the relevant regulatory obligation.
Purpose
The processing of your personal data serves the following purpose:
- Complying with the relevant legal obligation.
Legal basis
We base the processing of your personal data on the following legal basis:
- Processing your personal data is required to comply with relevant legal obligations.
We process your personal data based on Article 6 (1) (c) of the GDPR and the respective Union or EU Member State law provision.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
3.5 Product enquiries
In the case that you make an enquiry to dealers of Hero MotoCorp products, this enquiry may be shared with Hero MotoCorp. These enquiries may relate to any of the products and services we distribute.
Categories of personal data
The following information will be processed in relation to product enquiries:
- Your name;
- Your contact details such as telephone number or email address (depending on how you contacted the dealer); and
- The content of your enquiry.
Purpose
The processing of your personal data serves the following purpose:
- Answering your product enquiry.
Legal basis
We base the processing of your personal data on the following legal bases:
- Your personal data are processed based on your consent given when you make a product enquiry.
We process your personal data based on Article 6 (1) (a) of the GDPR.
- Processing of your personal data is necessary for the performance of the contract with you or in order to take steps at your request prior to entering into a contract with you.
We process your personal data based on Article 6 (1) (b) of the GDPR.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve this purpose. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
4 PROCESSING OF YOUR PERSONAL DATA WITH REGARD TO YOU AS A BUSINESS PARTNER
4.1 Business execution with partners/dealers
We regularly enter into contracts with business partners (such as dealers, or suppliers). It is predominantly legal entities with whom we maintain contractual relationships. However, natural persons can also act in a business capacity as sole traders. As part of the performance of contracts with our business partners, certain personal information about you as our contact at the business partner will be processed. We only process your personal data related to the business relationship.
Categories of personal data
The following information will be processed in relation to the business execution:
- Your name;
- Your contact details such as telephone number or email address;
- Sole trader’s VAT registration number;
- Other official identifiers (e.g. [TBD]);
- Any recordings captured through communication platform(s) (such as telephone recordings, Microsoft Teams, Zoom, etc.); and
- Details contained in business registration documents, third-party due diligence documents, trade references and credit checks.
Purpose
The processing of your personal data serves the following purposes:
- Processing of business transactions and maintain our relationship with our business partner.
Legal basis
We base the processing of your personal data on the following legal bases:
- If you are personally acting as our business partner, the processing of your personal data is necessary for the performance of the contract with you or in order to take steps at your request prior to entering into a contract with you.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- If you are our contact at the business partner, we have a legitimate interest in performing and maintaining the contract and relationship with our business partner.
We process your personal data based on Article 6 (1) (f) of the GDPR.
- For some processing of your personal data we shall obtain your consent where necessary in accordance with Article 6 (1) (a) of the GDPR.
This applies in particular but not limited to the recording of telephone calls.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time.[…]. For more information on the storage period, see Section 6 of this Privacy Notice.
4.2 Support and communication
In the context of our business relationship, Hero MotoCorp will support you with your enquiries related to the business relationship and provide you with information on the relationship.
Categories of personal data
The following information will be processed when communicating with you:
- Your contact details such as telephone number or email address;
- Any personal data as part of communicating with you, including, where applicable, telephone conversations with you;
- Data relating to your request or concerns, such as the subject of your request or our communication with you; and
- The data necessary to support you with your request.
Purpose
The processing of your personal data serves the following purposes:
- Communicating with you when you have raised questions or other concerns;
- Handling and responding to your enquiries and concerns;
- Communicating with you outside of enquiries and concerns, for example, for information purposes or for the fulfilment of legal or contractual obligations; and
- Should we record telephone calls, this is done for quality assurance and training purposes and improving our support.
Legal basis
We base the processing of your personal data on the following legal bases:
- If you are personally acting as our business partner, the processing of your personal data in connection with our support and communication with you is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.
We process your personal data based on Article 6 (1) (b) of the GDPR.
- If you are our contact at the business partner, we have a legitimate interest in conducting business relations with our business partner in proper manner and in performing of the contract by providing efficient support information on our relationship.
We process your personal data based on Article 6 (1) (f) of the GDPR.
- We provide you with certain support services outside of an existing contract.
We process your personal data based on Article 6 (1) (f) of the GDPR.
We have a legitimate interest in helping you in the event of questions about our offers and services and in ensuring the satisfaction of our (former and future) business partners.
- For some processing of your personal data we shall obtain your consent where necessary in accordance with Article 6 (1) (a) of the GDPR.
This applies in particular but not limited to the recording of telephone calls.
Storage period
In principle, we shall process your personal data only for as long as is necessary to achieve these purposes. We will retain your personal data only for as long as such information is necessary for the purposes it was collected for. The retention period for personal data may also be affected by the requirements of applicable laws. In all cases information may be held for a longer period where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or subject to law, a shorter period where the individual objects to the processing of their personal data. We shall take reasonable steps to destroy or permanently delete personal data that is no longer needed, including that processed by third parties engaged by us from time to time. For more information on the storage period, see Section 6 of this Privacy Notice.
5 STORAGE PERIOD
We shall store your data only for as long as is necessary to achieve the purposes of the processing or for as long as we have a legitimate interest in continuing to store your data. The storage period for your personal data depends in particular on the category of personal data processed and the purpose of the processing. Storage of your data is also considered based on your consent to its storage.
Finally, we take into account statutory storage periods, which may require us to keep your data for a certain period of time. Your data will therefore be stored if this is provided for by the European or national legislator in European Union regulations, laws or other provisions to which we are subject. Corresponding requirements are also found in particular in commercial and tax legislation or derive from the regular statutory limitation periods.
In the event of a legal dispute, we will keep the personal data we need for our legal defense until the final conclusion of the proceedings.
For more information on the storage period, please contact us via the contact details to be found under Section 1 of this Privacy Notice.
6 RECIPIENTS OF YOUR PERSONAL DATA
6.1 Recipients within the Hero MotoCorp Group
We share your personal data with other Hero MotoCorp Group companies in certain cases. The processing by these Hero MotoCorp Group companies is regularly carried out on our behalf. The processing of your personal data may also be carried out under the sole controllership of the Hero MotoCorp Group company receiving your data or under the joint controllership of that company with us.
If we share your personal data with other controllers, this will in principle be done only if this is necessary for the performance of a contract with you, if we or the third party have a legitimate interest in this or if you have agreed to this.
Processing of your personal data by another Hero MotoCorp Group company on our behalf is carried out on the basis of a contract for processing data on behalf of a controller within the meaning of the GDPR.
In the case of joint controllership, we shall conclude an agreement on processing under joint controllership. This agreement shall lay down, inter alia, the obligations of the joint controllers in relation to compliance with the requirements of the GDPR. We shall be happy to provide you with the essential elements of this agreement on request. To this end, please contact us using the contact details that can be found in Section 1 of this Privacy Notice.
6.2 Recipients outside the Hero MotoCorp Group
In addition to recipients of the Hero MotoCorp Group, we share your personal data with third parties, in relation to individual processing operations and taking into account the data protection regulations. These third parties include service providers that process your personal data on our behalf and service providers that provide services for us that are associated with the processing of your personal data. The processing of your personal data may also be carried out under the sole controllership of the third parties receiving your data or under the joint controllership of those third parties with us.
If we share your personal data with other controllers, this will in principle be done only if this is necessary for the performance of a contract with you, if we or the third party have a legitimate interest in this or if you have agreed to this.
In connection with the processing of your personal data, we use the following categories of service providers:
- IT Service Providers (Data Hosting Providers);
- Support (Customer Support); and
- Lawyers, auditors and tax advisers.
We also pass on your data to the authorities and courts, as far as we are obligated by the GDPR or the law of the EU Member States.
Processing of your personal data by third parties on our behalf is carried out on the basis of a contract for processing data on behalf of a controller within the meaning of the GDPR.
In the case of joint controllership, we shall conclude an agreement on processing under joint controllership. We shall be happy to provide you with the essential elements of this agreement on request. To this end, please contact us using the contact details that can be found under Section 1 of this Privacy Notice.
7 TRANSFER OF YOUR PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN ECONOMIC AREA
Regardless of where your personal data is processed, the highest priority for us is that the level of protection guaranteed by the GDPR is always ensured.
If we transfer personal data to recipients outside the European Economic Area, we comply with the requirements of Chapter V of the GDPR. If we work with third parties or use service providers that may transfer your personal data to countries outside the European Economic Area, we shall oblige those third parties or service providers to comply with the requirements of Chapter V of the GDPR.
We point out that not all countries outside the European Economic Area have a level of data protection that is recognised as adequate by the European Commission (so-called “adequacy decision”). A list of the countries for which an adequacy decision has been adopted can be found at the following link: Adequacy decisions (europa.eu).
Where an adequacy decision has not been adopted, we conclude the standard contractual clauses adopted by the EU Commission with the recipients of your personal data ((EU) 2021/914 of 4 June 2021 – C (2021) 3972, OJ EU No L 199/31 of 7 June 2021). For transfer to other controllers, we use Module One of these standard contractual clauses and for transfer to our processors we use Module Two. If necessary, in addition to concluding the standard contractual clauses we shall also take additional measures to protect your personal data.
You can ask us for an overview of the recipients in countries outside the European Economic Area and information on the measures we have taken to ensure the level of protection of the GDPR at any time via the contact details specified under Section 1 in this Privacy Notice.
8 YOUR RIGHTS AND ASSERTING
If you wish to assert your rights as specified below, you can contact us at any time and without any required form via the communication channels specified in this Privacy Notice. By email and on the other communication channels, you can reach Hero MotoCorp direct and the data protection officer of Hero MotoCorp direct via the contact details specified under Section 1 of this Privacy Notice.
8.1 Right to information
You have the right to request confirmation as to whether or not your personal data will be processed. When we process your personal data, you have a right to information about this personal data and certain information required by law. For more information on your right to information, see Article 15 GDPR.
8.2 Right to rectification
ou have the right to request the rectification of incorrect personal data concerning you without delay. Taking into account the purposes of processing, you have the right to request the completion of incomplete personal data. For more information on your right to rectification, see Article 16 GDPR.
We always strive to ensure the accuracy of your personal data. We therefore ask you to notify us immediately of any changes to your data (such as changes in address), so that we can ensure that your personal data is up-to-date.
8.3 Right to erasure
If the legal requirements are met, you may request us to erase your personal data immediately. This shall be the case, in particular, where:
Your personal data will no longer be required for the purposes for which it was collected or otherwise processed;
The processing of your personal data is based on your consent, you revoke this consent and we cannot base the processing on another legal basis;
You have objected to the processing of your personal data on grounds relating to your particular situation and there are no overriding grounds for the processing of your personal data;
If your personal data have been passed on to third parties and we are obligated to erase your personal data, we will inform these third parties about the erasure, insofar as this is required by law.
We would like to point out that your right to erasure is subject to restrictions. For example, we may not erase any personal data that we have to keep further due to legal requirements. Data that we need in order to assert, exercise or defend legal claims are also excluded from your right to erasure. For more information on your right to erasure, see Article 17 GDPR.
8.4 Right to restriction of processing
If the legal requirements are met, you may request a restriction on the processing of your personal data. This is particularly the case where:
You contest the accuracy of your personal data. The processing of your data will be restricted for a period enabling us to verify the accuracy of your personal data;
The processing of your personal data is not lawfully carried out and you require a restriction on the use of your personal data instead of the erasure of your personal data;
We no longer need your personal data for the purposes of processing, but you need these data for the establishment, exercise or defence of legal claims;
You have objected to the processing of your personal data on grounds relating to your particular situation, as long as it is not clear whether our legitimate grounds for processing outweigh your grounds.
For more information on your right to restriction of processing, see Article 18 GDPR.
8.5 Right to data portability
You have the right to receive the personal data you have provided us and which we process for the fulfilment of the contract, on the basis of your consent or by automated procedures, in a structured, customary and machine-readable format. You also have the right, in the event that the aforementioned conditions are met, that we transmit these data directly to a third party, insofar as this is technically feasible. For more information on your right to data portability, see Article 20 GDPR.
8.6 Withdrawal of consent
If you have given your consent to the processing of your personal data, you can revoke it at any time with effect for the future. The lawfulness of the processing of your data up until revocation remains unaffected. Click Here
8.7 Right to object to data protection authorities
If you consider that the processing of your personal data violates applicable data protection laws, you may lodge a complaint with a data protection supervisory authority, in particular the data protection supervisory authority at your location, place of work or place of alleged infringement.
8.8 Right to object to processing
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Right to object to the processing of your personal data during processing based on our legitimate interests Insofar as we process data on the basis of a legitimate interest, you can object to the processing at any time for reasons that arise from your particular situation. We will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. We assume that, in the course of processing on the basis of a legitimate interest, we can normally prove such compelling legitimate grounds for protection, but we examine and evaluate each objection individually. For more information on your right of objection, see Article 21 GDPR. |
9 CHANGES TO THIS PRIVACY NOTICE
In this Privacy Notice, we will always keep you fully and completely informed about the processing of your personal data. This requires that we update this Privacy Notice regularly. We therefore recommend that you consult this Privacy Notice regularly.