Privacy Statement on shared analysis and marketing activities on this specific Mercedes-Benz website by Mercedes-Benz Hong Kong Limited (MOC); Mercedes-Benz AG (MBAG) and Mercedes-Benz Mobility AG (MBM)
This privacy statement describes how the three entities listed above process your personal data for the purpose of shared analysis and marketing activities on this specific website. Protecting your personal data is a high priority for all parties of this privacy statement, and is taken into account for all business processes. This privacy statement provides you with a detailed summary regarding the processing of your personal data in relation to the analysis and marketing activities mentioned below.
"Personal data", according to the General Data Protection Regulation of the European Union (GDPR), means all information that relates to a natural person who has been or can be identified. You will also find information about what rights you are entitled to regarding the processing of your personal data according to the GDPR.
The way Mercedes-Benz entities process personal data within, or related to individuals within, the European Union and European Economic Area is always based on the Mercedes-Benz Group Data Protection Policy EU (https://group.mercedes-benz.com/data-protection-policy).
Who is responsible for processing my personal data, and whom can I contact on the topic of data protection?
The (joint) controllers responsible for processing your personal data for shared analysis and marketing activities on this specific website are:
Mercedes-Benz Hong Kong Limited
5th Floor, 60 Ka Yip Street,
Chai Wan, Hong Kong
Email: mbhk_marketing@mercedes-benz.com
Responsible officer: [Clare But / Risk Management Manager]
Mercedes-Benz AG
Mercedesstr. 120
70372 Stuttgart, Germany
Email: dialog.mb@mercedes-benz.com
Mercedes-Benz Mobility AG
Siemensstr. 7
70469 Stuttgart, Germany
Email: mbm@mercedes-benz.com
Data protection officer for MBAG and MBM:
Mercedes-Benz Group AG
Group Data Protection Officer
HPC E600
D-70546 Stuttgart, Germany
Email: data.protection@mercedes-benz.com
MOC and MBAG as well as MBAG and MBM have concluded joint controllership agreements according to Art. 26 GDPR. For more information, please see the table below.
Where does my data come from and what data is processed?
Whenever you visit this specific website and if you have consented the following categories of data are stored and shared with MBAG, MBM, Zung Fu Company Limited, Zung Fu Motors (Macau) Limited and Mercedes-Benz Financial Services Hong Kong Limited:
Server-Logfiles: Certain information about the browser, operating system and IP address (only very short-term) you are using; the date and time of your visit; the status of the interaction (e.g. whether you were able to access the website or received an error message)
Clickstream Data: Your usage of the website and its features; any search phrases you entered; how often you visit the website and the campaign from which you accessed this specific website
Online identification features: Your Cookie ID, Web Client or/and App ID
Geo-location data: The country and the city from where you accessed our website (derived from the IP address)
Payment information: Payment method you used while purchasing something on this specific website
MOC processes that data about your visit on this specific website together with the other controllers -depending on your consent- using the following technologies:
• For analysis purposes:
- Google Analytics 360
• For marketing purposes:
- Salesforce Interaction Studio
- Salesforce Audience Studio
- Adobe Target
It is obligatory for you to provide the aforementioned data to us. Otherwise, some of the functions or features of this specific website may not be fully functional.
For what purpose and on what legal basis is your personal data processed?
The personal data collected during your visit on this websites is used for conducting personalization and targeted advertising measures, market research and control and business and profitability analysis. Moreover, the website usage behavior is analyzed to improve website usability and enhance digital products and campaigns. In addition, that data is used for statistical reports.
Within the scope of the joint controllership, your personal data is processed based on your consent according to Art. 6 (1) (a) GDPR. Your consent is optional and may be withdrawn at any time through the Consent Management Platform of this specific website. The lawfulness of data processing before such withdrawal remains unaffected by the withdrawal.
Will my data be sent to a third country?
When passing on data to third parties based on your consent, personal data may be provided from within the European Union ("EU") or the European Economic Area (“EEA”) to recipients in countries outside the EU or EEA, i. e., in a so-called third country.
In some third countries, from the EEA's point of view, an adequate level of personal data protection (so-called "adequacy") exists, in compliance with EU standards. With other recipients in third countries, MBAG and MBM agree on the use of EU standard contractual clauses, binding corporate rules or other applicable instruments to create an "adequate level of protection" according to legal requirements. For more information, please contact one of the controllers.
How long will my data be stored?
Your personal data will be stored until the purpose for which it was collected and processed has been fulfilled. Beyond this period, data storage only takes place to the extent made necessary by applicable legislation, regulations or other legal provisions in the European Economic Area or in third countries if these have an adequate level of data protection. If personal data must be retained on such basis, the relevant personal data are flagged to restrict their further processing.
What rights do I have under GDPR?
According to GDPR, you have certain rights regarding the processing of your personal data. Making you aware of these rights is very important to Mercedes-Benz:
Right of access: You can request access to your personal data processed by us (Art. 15 GDPR).
Right to correction of inaccurate data: You have a right to request correction of your personal data, in case it is inaccurate (Art. 16 GDPR).
Right to deletion: You have the right to request deletion of you personal data. The criteria allow you to request the deletion of your personal data if, for example, it is no longer needed for the purposes for which it was collected or otherwise processed. You can also demand the deletion of your personal data if it is unlawfully processed, or if you have rightfully objected to the processing of your data, revoked your consent to the same or there is a legal obligation to delete it (Art. 17 GDPR).
Right to restriction of processing: You have the right to demand a restriction of the processing of your data. This right especially applies for the duration of the review if you have disputed the accuracy of your personal data, as well as in the case that, for an existing right to deletion, you request restricted processing instead of erasure. Furthermore, there will be restricted processing if the data is no longer required for legitimate purposes, but you still need the data in order to assert, exercise or defend legal rights, as well as if the successful assertion of an objection is in dispute between you and MOC, MBAG and/or MBM (Art. 18 GDPR).
Right to data portability: You have the right to receive the personal data you have provided in a structured, common, machine-readable format (Art. 20 GDPR), insofar as the data has not been deleted already.
Right to lodge a complaint with a supervisory authority: If you feel that processing of your data is not in line with the GDPR, you have the right to lodge a complaint with a supervisory authority in an EU member state, e.g., a data protection agency responsible for your place of residence, workplace or location where the alleged data protection violation occurred (Art. 77 GDPR).
If you wish to assert one of your rights or receive more information, please contact one of the controllers stated above. Preferably, please contact the MOC.
Appendix - Details of joint controllership - Data sharing in the field of marketing and analysis on this Mercedes-Benz website in the event of given consent
1. Controller
Mercedes-Benz Hong Kong Limited
5th Floor, 60 Ka Yip Street, Chai Wan, Hong Kong
Email: mbhk_marketing@mercedes-benz.com
(“MOC“)
Mercedes-Benz AG
Mercedesstr. 120
70372 Stuttgart
Email: dialog.mb@mercedes-benz.com
(“MBAG”)
Mercedes-Benz Mobility AG
Siemensstr. 7
70469 Stuttgart
Email: mbm@mercedes-benz.com
(“MBM”)
2. Purpose of joint processing
The purpose of the sharing and further processing of personal data in the field of marketing and analysis on this Mercedes-Benz website in the event of given consent is to carry out analysis measures to recognize website user behavior, to improve the user-friendliness of the websites and to improve digital products and campaigns. In addition, the purpose is to provide Mercedes-Benz-internal market and target achievement reports, such as generated leads, (re-)targeting and personalization measures.
3. Legal Basis of the processing of personal data
Art. 6 (1) (a) GDPR, insofar as the data subjects have given their consent to the joint processing of their personal data for one or more specific purposes.
4. Responsibilities
a. Information obligations:
As controllers, MOC and MBAG are obliged to provide data subjects with information about the processing pursuant to Articles 13 and 14 GDPR. This includes, in particular, purposes and legal bases of the processing of personal data, recipients of personal data, the duration of processing and transfers to third countries. The controllers support each other in fulfilling the information obligations and provide each other with the necessary information on the relevant data processing activities.
b. Data subject rights:
In the relationship between MOC and MBAG, MOC is responsible for providing the data subjects with information about the essential contents of the joint controllership and the rights of data subjects pursuant to Articles 12 - 22 GDPR (e.g. access, correction, erasure).
c. Information obligations:
As controllers, MBAG and MBM are obliged to provide data subjects with information about the processing pursuant to Articles 13 and 14 GDPR. This includes, in particular, purposes and legal bases of the processing of personal data, recipients of personal data, the duration of processing and transfers to third countries. The controllers support each other in fulfilling the information obligations and provide each other with the necessary information on the relevant data processing activities.
d .Data subject rights:
In the relationship between MBAG and MBM, MBAG is responsible for providing data subjects with information about the essential contents of the joint controllership and the rights of data subjects pursuant to Articles 12 - 22 GDPR (e.g. access, correction, erasure).
5. Categories of data subjects
Unknown website visitors
6. Types of personal data
a. Server-Logfiles
b. Clickstream Data
c. Online identification features
d. Geo-location data
e. Payment information
No special categories of personal data
Terms and Conditions
Hong Kong market only
This website ("Site") is intended for residents of the Hong Kong Special Administrative Region (”Hong Kong”) only. All information on this Site is intended only for the Hong Kong market. Mercedes-Benz Group makes no representation that materials in this Site are appropriate or available for use in locations other than Hong Kong. Mercedes-Benz Group may make changes to, alter or amend the information contained on this Site and/or these terms and conditions at any time without prior notification. Please review this Site and/or these terms and conditions periodically. Mercedes-Benz Group does not have any responsibility to keep the Site updated on a regular basis or notify you of the changes.By using this Site, you signify your assent to the Mercedes-Benz Group Site terms and conditions and the Privacy Policy. If you do not agree to these terms and conditions or the Privacy Policy, please do not use this Site. Continued use of this Site shall constitute your acceptance of any revised terms and conditions or amendments to the Privacy Policy. Further, by using this Site, you agree to indemnify Mercedes-Benz Group, its subsidiaries and affiliates from and against any and all claims, demands, judgments, costs, liabilities, expenses (including attorneys´ fees) and damages arising out of claims resulting from the use of this Site by you or any third person.
No representation made about the information on this Site
Whilst Mercedes-Benz Group has endeavoured to make the information provided on this Site as accurate as possible, Mercedes-Benz Group makes no warranties or representations, express or otherwise, as to the accuracy, timeliness, validation, availability, completeness or non-infringement on another party´s right(s) of the information contained on this Site. Mercedes-Benz Group disclaims any and all responsibility or liability for any errors, inaccuracies or omissions. Your use of and browsing of this Site is solely at your own risk. In particular, Mercedes-Benz Group does not make any representation with respect to the Mercedes-Benz products on this Site. The accuracy of such information cannot be guaranteed particularly since this information is subject to change. Specific statements of availability and such reference do not imply that Mercedes-Benz Group intends to announce such products, services etc in your country or region. This Site shall not be used or relied upon by you as a substitute for information that is available to you from an authorized Mercedes-Benz dealer. Always contact your dealer for complete details regarding the prices, products, services etc which may be available to you for ordering. Mercedes-Benz Group shall not be liable for any loss or damage you may suffer as a result of any information on this Site that may be inaccurate or incorrect.
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While Mercedes-Benz Group makes all reasonable efforts to ensure that all material on this Site is correct, accuracy cannot be guaranteed and Mercedes-Benz Group does not assume any responsibility for the accuracy, completeness or authenticity of any information contained on this Site. This Site and all information and materials contained herein, is provided to you "as is" and to the extent permitted by law without warranty of any kind, either express or implied, including but not limited to, warranties in connection with the uninterrupted or continuous availability of the Site; representations about the suitability of the information, products and/or services contained on this Site for any purpose, implied warranties of merchantability; fitness for a particular purpose or non-infringement with respect to the Site and any services provided by Mercedes-Benz Group hereunder. In no event shall Mercedes-Benz Group be liable to any party for any direct, indirect, special or other consequential damages for any use of this Site or any other hyperlinked web site, including without limitation, any loss of profits, business interruption, loss of programs of other data on your information handling system or otherwise, even if we are expressly advised of the possibility of such damages.
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Off site pages and links
The Site may contain links to non-Mercedes-Benz Group web sites. The links are provided for reference only and they do not in any way imply any endorsement of any of the products or information contained or offered by such sites or any association with their operators. Mercedes-Benz Group assumes no responsibility in any way or liability for access to or the contents contained on those sites or their security and you use these links solely at your own risk. Accordingly, you agree to hold harmless Mercedes-Benz Group, its subsidiaries and affiliates, and the shareholders, officers, directors, employees and agents of any of them from and against any and all claims, demands, judgments, costs, liabilities, expenses (including attorneys´ fees) and damages arising out of claims resulting from hyperlinking.
Privacy Policy
Mercedes-Benz Group appreciates your interest in our products and your visit to this Site. Your privacy is important to us and we want you to feel comfortable visiting this Site. We take online privacy seriously. Personal data collected during visits to our web sites is processed by us in accordance with the policy described below. This Site may include, however, links to other web sites that are not covered by this Privacy Policy. Mercedes-Benz Group respects your privacy. We follow a policy of not selling or exchanging personal data to or with any person or company outside of the Mercedes-Benz Group or our Dealers or agents.
Collection and Processing of Personal Data
When you visit our Site, our web server automatically records the name of your internet domain, internet service provider, browser and operating system used to access our Site, the web site from which you visit us, the web sites you actually visit and the date and time of each visit. This information allows us to measure site and user activity to tailor information to suit your individual preferences. Mercedes-Benz Group uses cookies to follow the preferences of our visitors to optimise your Site visit accordingly. "Cookies" are elements of data that a web site can send to your browser, which may then store the cookie on your hard drive. Cookies are used in almost all major web sites. The purpose is to save you time and provide you with a more meaningful visit. If you are concerned about cookies, you may modify your browser settings to notify you when you receive a cookie. If you do not know how to modify your browser settings please consult your browser documentation or supplier web site. However, it is possible that some parts of the Site will not function properly if you modify your browser settings. Further, we will not be able to recognize you as a visitor over time. Additional personal data is only stored if volunteered by you, for example in the context of a survey, a contest or a request for information (such as new vehicle information alerts, promotions and mailed brochures). When you choose to share such information, you agree to let us use it in a manner appropriate to the nature of the information and which is used to fulfill your request. You should be aware that when you voluntarily disclose personal information in public areas of our web sites, such as bulletin boards, this information may be seen and used by others. We urge you to exercise good judgement when sharing personal information in these forums.
Use and Disclosure of Personal Data
Mercedes-Benz Group may use your personal data for the purpose of technical administration of the Site, customer fulfilment and administration, product surveys and marketing. Your personal data may be made available to our dealers, agents or other Mercedes-Benz Group companies. We are required to disclose your data to governmental authorities where stipulated by law. Our employees, agencies, and dealers are obliged by us to respect confidentiality. Whilst we will use every effort to keep your data confidential, we cannot guarantee that such data will not be disclosed inadvertently or otherwise. Mercedes-Benz Group shall not be responsible for any harm that you or any person may suffer as a result of a breach of confidentiality in respect of your use of this Site or any information you transmitted to this Site.
Comments, Questions or Suggestions
Please note that any information, unsolicited suggestions, ideas or other submissions will be deemed not confidential and non-proprietary. By sending any comments, information or material, you grant Mercedes-Benz Group an unrestricted, irrevocable license to use, reproduce, display, perform, modify, transmit and distribute those materials or information, including posting on the Site´s bulletin board, and you also agree that Mercedes-Benz Group is free to use any ideas, concepts, know-how or techniques that you send us for any purpose whatsoever.
Freedom of Choice
Mercedes-Benz Group would like to use your data to inform you about our products and services and where applicable, request your opinions. Naturally your participation is completely voluntary.
Security
Mercedes-Benz Group uses all reasonable technical and organisational security measures in order to protect the data we have in our control against accidental or intentional manipulation, loss or destruction or unauthorised access. Our security procedures are continually enhanced as new technology becomes available but we cannot guarantee against any unauthorised access or accidental or intentional manipulation of your data. In the event of this, Mercedes-Benz Group shall not be responsible for any loss, damage or other direct or indirect consequences you or any third person may suffer as a result of breach of security.
Updates
When any privacy legislation and/or voluntary codes are introduced or our Privacy Policy is revised, this section may be updated from time to time.
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