Privacy Policy
VDA-QMC Quality Management Center Beijing Co., Ltd.
Release date: 16th September 2022
[Special Reminder] Welcome to the ITMT platform (hereinafter referred to as “ITMT”) provided by VDA-QMC Quality Management Center Beijing Co., Ltd.! ITMT is a platform for training overview of open course and online registration. The usage of the ITMT is on the condition that you accept all the terms of this policy. Please read carefully before using ITMT (Minors should read with a guardian) and understand this policy (especially the terms marked in bold/bold underline) to make an appropriate choice. When you agree to this policy, it means that you have agreed to our collection and processing of your personal information in accordance with this policy.
The outline of this Privacy Policy is as follows:
I. Most important information relating to data protection
1. What is the Policy about?
2. Which Personal Information are we processing? For what purpose?
3. Do we provide Personal Information to third parties?
4. Which measures do we take to protect your Personal Information?
5. Which rights do you have?
II. Detailed policy
1. Introduction
2. How we collect and use your Personal Information
3. How we use Cookies and other technologies
4. How we entrust others to process, provide, transfer, publicly disclose and store your Personal Information
5. How we protect your Personal Information
6. Your rights
7. How do we deal with Sensitive Personal Information
8. How does your Personal Information shift around the world
9. How to update this policy
10. Dispute resolution
PRIVACY POLICY
This Privacy Policy (“hereinafter referred to as “Policy”) is applicable to the ITMT Platform of VDA-QMC Quality Management Center Beijing Co., Ltd. (hereinafter referred to as “VDA QMC China”), including the website under Home (vda.cn).
VDA QMC China is responsible for processing your Personal Information collected through the use of the ITMT.
In this Policy, “VDA QMC China”, “we”, our” or “us” refers to:
VDA-QMC Quality Management Center Beijing Co.,Ltd.
Address:
5th Floor, Unit 0505P, Inside 101, Floor 3-24, Building 5, Yard 19, Dongfang East Road, Chaoyang District, Beijing
Email: dataprotection@vdachina.com.cn
I. Most important information relating to data protection
The laws and regulations in China and Europe require us to provide you with extensive information about data protection. Hereinafter you will find a brief summary of the most important contents of our Policy. In Section II. you can find a detailed Policy.
1. What is the Policy about?
1.1. In our Policy, we inform you how we process your Personal Information.
1.2. Personal Information refers to all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding the information processed anonymously. This for example includes your name, your address and your email.
1.3. The processing of Personal Information includes the collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. of personal information.
2. Which Personal Information are we processing? For what purpose?
We only use your Personal Information for registration and for providing services on our platform. We collect the following data:
• Registration: email address, password, telephone number, sex, name, date of birth, company name, department.
• Providing services: name, country, city, address, email address, contact information of the recipient of materials or invoices.
3. Do we provide Personal Information to third parties?
We will not provide your Personal Information to any other third parties without your consent to such providing of Personal Information unless otherwise provided for by laws and administrative regulations. All our employees as well as our service providers are obliged to comply with the data protection regulations and our guidelines.
4. Which measures do we take to protect your Personal Information?
We use safety protection measures that meet the industry standards to protect your Personal Information and prevent unauthorized access and divulgence, falsification and loss.
5. Which rights do you have?
5.1. You are inter alia subject to the following legal rights with regard to our processing of your Personal Information:
• Access to your Personal Information
• Correct and supplement your Personal Information
• Deletion of your Personal Information
• Change the scope of your authorization
• Receive a copy of Personal Information stored by us
• Restrict and object to processing
5.2. In addition, you can influence our processing activities by different measures on your own, e.g. settings on your browser. Please refer to the detailed Policy for further information.
II. Detailed policy
1. Introduction
1.1. This detailed Policy will help you understand the following:
• How we collect and use your Personal Information
• How we use Cookies and other technologies
• How we entrust others to process, provide, transfer, publicly disclose and store your Personal Information
• How we protect your Personal Information
• Your rights
• How do we deal with Sensitive Personal Information
• How does your Personal Information shift around the world
• How to update this policy
• Dispute resolution
1.2. We know the importance of Personal Information to you and will do our best to protect your Personal Information safely and reliably. We are committed to maintaining your trust in us and following the principles of legality, justification and necessity, participation, openness and transparency to protect your Personal Information. At the same time, we take appropriate security measures to protect your Personal Information according to current security standards.
2. How we collect and use your Personal Information
2.1. We will collect and obtain your Personal Information through the following channels and for following purposes:
2.1.1. Registration
To offer you the full functions of ITMT, we need you to provide basic registration or logging in information, including your email address, password, telephone number, sex, name, date of birth, company name, department. Please note that you can voluntarily fill in your other Personal Information including your position. If you only need to use basic functions such as browsing and searching, you do not need to register as an ITMT user and provide the above-mentioned information.
2.1.2. Providing services
Ordering services: While ordering services on ITMT, we will generate orders for you to order the services through the system and we will send you emails for confirmation of your orders, payment notices and etc.
Delivery services: We may need to deliver some materials to you, such as the invoices and certificates issued by VDA QMC China. Therefore, we need you to provide the delivery information, including the name, country, city, address, email address, contact information of the recipient. If you refuse to provide the information, we cannot complete the delivery services.
Order management: In order to display the history order record of your account and protect your after-sale rights and interests, we will collect the Personal Information of the order generated during the transaction and consumption record to display and facilitate your order management.
If you order services for others through ITMT, you need to provide the aforementioned Personal Information of the actual subscriber. Before providing the aforementioned Personal Information of the actual subscriber to us, you shall obtain the authorized consent of the actual subscriber.
2.2. Usage data
While using the platform, we also collect additional data that we analyze anonymously. With anonymous data it is impossible to identify an individual user. We analyze anonymous data to improve the usability of our service, e.g., by analyzing the device data or the operating system. We use other data, such as page views, to optimize our platform.
2.3. Exceptions for acquiring your consent
We will generally ask you for your consent before processing your Personal Information. Please be aware that in certain cases we are not required to ask you for your consent. These cases inter alia include:
• it is necessary for the conclusion or performance of a contract to which you are one of the parties,
• it is necessary for the performance of statutory duties or statutory obligations;
• it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
• such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of Personal Information is within a reasonable scope;
• it is necessary to process the Personal Information disclosed by you or other Personal Information that has been legally disclosed within a reasonable scope in accordance with the provisions of this Law; and
• other circumstances prescribed by laws and administrative regulations.
2.4. Additional information on the legal basis for data processing for persons residing in the European Union
The processing of your Personal Information for the purposes referred to in Article 2.1 and 2.2 is for the performance of a contract or for the implementation of pre-contractual measures in accordance with Article 6 (1) lit. b) GDPR.
2.5. We generally process your Personal Information until you request removal or deletion of your Personal Information, except we are required to store the Personal Information by applicable laws and regulations.
2.6. When we want to use your Personal Information for other purposes that we did not clearly state in our policy, we will ask for your consent beforehand.
3. How we use Cookies and other technologies
3.1. Server log files
Every access to our website and every retrieval of a file stored there is logged. The storage serves internal system-related and statistical purposes. The following are logged: name of the retrieved file, date and time of retrieval, amount of data transferred, notification of successful retrieval, web browser and requesting domain. In addition, IP addresses of the requesting computers are logged.
3.2. Cookies
The websites sometimes use so-called cookies. They serve the user-friendliness, effectiveness and security of the websites. Cookies are small text files that are stored locally in the cache of the website visitor's Internet browser. The cookies enable the recognition of the Internet browser. You can prevent the acceptance of cookies by setting your browser accordingly. If you choose this option, you may not be able to use all the interactive features of our websites and all our services.
3.3. Session cookies
To enable you to browse quickly and to ensure that information you enter is remembered, we use session cookies on our websites. Your data remains stored in the cookie file in your browser during the connection but will be deleted when you exit the browser depending on the setting of your browser program.
3.4. Other cookies
We use the cookies for logging into the frontend homepage https://vdachina.com.cn/ by persons who accesses the homepage. e.g. view settings, search input.
3.5. Plug-in tool
The plug-in tool for the registration forms act as an interface between partially incompatible systems when importing and exporting data from and to various software systems.
3.6. Additional information on the legal basis for data processing for persons residing in the European Union
The processing of your Personal Information for the purposes described in Articles 3.1 to 3.5 is necessary for the purposes of our legitimate interests pursuant to Article 6 (1) lit. f) GDPR. Our legitimate interest lies in the statistical evaluation of your user behavior, maintaining the security of our website and in order to continuously optimize our website and improve the marketing of our platform.
4. How we entrust others to process, provide, transfer, publicly disclose and store your Personal Information
4.1. Entrusting others to process your Personal Information
In certain cases, we use so-called data processors that support our activities with their services (this includes services to store information, technical support, marketing, analysis). These third-party service providers have access to your Personal Information needed to perform their duties but cannot use this information for any other purpose. These service providers are obliged to process Personal Information in accordance with the provisions of this Policy and our instructions.
4.2. Providing your Personal Information to others
We will not provide your Personal Information to any company, organization or individual other than us unless we obtain your separate consent. When we provide your Personal Information to other personal information processors based on your consent, we will inform you of the recipient's name or name, contact information, processing purpose, processing method and type of personal information.
4.3. Transfer of your Personal Information in special circumstances
In the case of merger, division, dissolution or declaration of bankruptcy, etc., these may involve the transfer of your Personal Information. In such a case, we will inform you of the name and contact information of companies and organizations that receive your Personal Information and require the companies and organizations to continue to be bound by this Policy. If the company or organization wishes to use the Personal Information for other purposes than described in this Policy, they shall ask you for your consent to process your Personal Information again.
4.4. Public disclosure of your Personal Information
We will not disclose your Personal Information publicly, except in circumstances where you consent to such public disclosure or in the event that we must publicly disclose your Personal Information in accordance with the requirements of laws, regulations, mandatory administrative enforcement or judicial requirements.
4.5. Storage of your Personal Information
Out of business needs, we will store your Personal Information on servers of Verband der Automobilindustrie in Germany. This means that your Personal Information will be transferred to, or accessed from a foreign jurisdiction. We ensure that your Personal Information is adequately protected in Germany as in the People's Republic of China. For the cross-border data transfer, we hereby ask for your separate consent.
Information of the storage entity is as below.
Name: Verband der Automobilindustrie
Address: Behrenstr. 35, 10117 Berlin, Germany
Contact information: Tel.:+49 30 897842-0
Fax:+49 30 897842-600
E-Mail: info(at)vda.de
Processing purpose: To be entrusted to store Personal Information we collect in China
Processing method: Storage
Kinds of Personal Information: All Personal Information we collect in China through ITMT.
You can reach the data protection officer of Verband der Automobilindustrie at the above address or by e-mail: datenschutz(at)vda.de.
We will store your Personal Information on servers in Germany just for the time period that we offer you the platform. Therefore, we keep your Personal Information for as long as is necessary for the purposes for which it is processed. After this period, your Personal Information will be automatically purged from our systems unless legislation requires us to keep your Personal Information for a diverging period.
5. How we protect your Personal Information
5.1. We use safety protection measures that meet the industry standards to protect your Personal Information and prevent unauthorized access and divulgence, falsification and loss. Our protection measures include for example:
• formulating internal management systems and operating procedures;
• implementing category-based management of Personal Information;
• taking corresponding technical security measures such as encryption and de-identification;
• reasonably determining the authority to process Personal Information and conducting security education and training for relevant employees on a regular basis;
• formulating and organizing the implementation of emergency plans for Personal Information security incidents; and
• other measures stipulated by laws and administrative regulations.
5.2. We take all reasonable and feasible measures to ensure that we only collect Personal Information necessary for our purposes.
5.3. In the unfortunate event of a Personal Information security incident, we will act in accordance with the requirements of laws and regulations and take the corresponding legal responsibilities. We will inform you about the basic situation of the security incident, measures we have taken or will take to deal with the incident and advice how you can prevent and reduce risks independently. We will inform you in time by mail, letter, telephone or push notice. If it is difficult for us to inform each person one by one, we will make an announcement in a reasonable and effective way.
5.4. At the same time, we will also take the initiative to report the disposal of a Personal Information security event in accordance with the requirements of the regulatory authorities.
6. Your rights
In accordance with relevant laws, regulations and standards in China and other countries and regions, we ensure that you exercise the following rights for your Personal Information.
6.1. Access to your Personal Information – Information right
You have the right to access your Personal Information processed by us unless stipulated otherwise in laws and regulations.
6.2. Correct and supplement your Personal Information
When you find that we are dealing with your Personal Information wrong or incomplete, you have the right to ask us to make corrections or supplementary.
6.3. Deletion of your Personal Information
In the following cases, you can request us to delete your Personal Information:
• If we deal with your Personal Information in violation of laws and regulations;
• If we collect and use your Personal Information, but have not received your consent;
• if we deal with your Personal Information in violation of an agreement with you;
• if you no longer use our platform;
• if you withdraw your consent; or
• if we no longer provide you with services, or the storage period has expired.
If the storage period as stipulated by laws and administrative regulations does not expire, or the deletion of Personal Information is difficult to be realized technically, we will stop the processing other than storage and necessary security protection measures.
6.4. Change the scope of your authorization
For the collection and use of additional Personal Information, you have the right to revoke consent granted with effect for the future. This means that your Personal Information will no longer be processed for this purpose and will also be deleted. Please note that that the revocation does not impact the legality of processing for which consent has been granted up to the revocation. If you wish to retract your consent, simply send us an email to dataprotection@vdachina.com.cn with your name and contact. You do not have to state a reason for your retraction.
6.5. Receive a copy of Personal Information stored by us
You have the right to receive a copy of your Personal Information stored by us unless if there are circumstances in which your Personal Information should be kept confidential as required by laws or administrative regulations or does not need to be informed.
6.6. Restrict and object to the processing
You have the right to restrict or refuse us to process your Personal Information, unless otherwise provided for by laws and administrative regulations.
6.7. How to exercise your rights
If you want to exercise any of your rights mentioned above, you can send an email to dataprotection@vdachina.com.cn. We will reply to your request generally within 30 days.
To ensure security, you may need to provide a written request or prove your identity in other ways. We may first ask you to verify your identity and then reprocess your request.
6.8. Additional information on User Rights for persons residing in the European Union
If you are residing in the European Union, the legal bases for your rights are as follows. You have the right to withdraw your consent under Article 7 GDPR, the right to information under Article 15 GDPR, the right to rectification under Article 16 GDPR, the right of deletion under Article 17 GDPR, the right to restrict the processing under Article 18 GDPR, the right to data transferability under Article 20 GDPR and the right to objection under Article 21 GDPR. The restrictions under § 34 and § 35 BDSG apply to the right of information and to the cancellation request. In addition, you have a right of appeal to a data protection supervisory authority under Article 77 GDPR in conjunction with § 19 BDSG.
7. How do we deal with Sensitive Personal Information?
Please note that no Sensitive Personal Information will be requested for the use of the ITMT. If we find ourselves collecting Sensitive Personal Information, we will delete relevant data as soon as possible.
8. How does your Personal Information shift around the world?
8.1. We will only process your Personal Information in the People's Republic of China and the European Union. We will not transmit your Personal Information to other countries without your separate consent.
8.2. Additional information on the legal basis for data processing for persons residing in the European Union
Where Personal Information is transferred from the European Union to China, the legal basis for this transfer is Article 49 (1) lit. b) GDPR.
9. How to update this policy
9.1. Our Policy may change.
9.2. Without your explicit consent, we will not reduce your rights in accordance with this Policy. We will publish any changes to this Policy on this website.
9.3. For major changes, we will also provide additional notices.
The major changes referred to in this Policy include, but are not limited to:
• Significant changes have taken place in our service model, such as the purpose of processing Personal Information, the type of Personal Information processed, the use of Personal Information, etc.;
• We have undergone major changes in terms of ownership structure, organizational structure of our company, and so on. Such as changes in the ownership structure caused by business adjustments, bankruptcy or mergers, etc.;
• The main objects of Personal Information sharing, transfer or disclosure are changed;
• Your right to participate in the handling of Personal Information and the manner in which it is exercised has undergone significant changes;
• Internal Responsibilities for Personal Information security, contact methods and complaint channels change; and
• The Personal Information Security Impact Assessment Report indicates that there is a high risk associated with our platform.
9.4. We will also file the old version of this policy for you to consult.
10. Dispute resolution
10.1. Do you have any questions with regard to the handling of your Personal Information or Personal Information protection? Do you have any suggestions or a matter you want to discuss? Please speak to our responsible person for data protection about this:
In China
Person in charge for personal information protection: Tilman Tillmann
Contact Information:
Address: 5th Floor, Unit 0505P, Inside 101, Floor 3-24, Building 5, Yard 19, Dongfang East Road, Chaoyang District, Beijing, China
Email: dataprotection@vdachina.com.cn
In Europe (acting as representative of VDA QMC China, Article 27 GDPR):
Contact Information:
Address: Behrenstr. 35, 10117 Berlin, Germany
Email: datenschutz(at)vda.de
In general, we respond within 30 days.
10.2. If you are not satisfied with our reply, especially if you think the way we process your Personal Information violates your legitimate rights and interests, you can also find a solution through the responsible People`s Court or relevant government authorities at VDA QMC China`s location of business.