This Privacy Policy (the “Policy”) applies whenever a person makes use of or is interacting with the Showpad Tool (the “Tool”) under any form of a user account, or, as a Third Party Data Subject being allowed (limited) access by an owner of a user account to the Tool. This Privacy Policy equally applies to any other Showpad products and services (including front-end clients (e.g. the Showpad mobile application), Web-Interface (e.g. plugins) and/or Connectors to third party applications) interacting to the Tool.
Whenever you use or interact with the Tool, Goodyear Dunlop Tires Operations S.A., a company organized and existing under the laws of the Grand Duchy of Luxembourg, having its registered office at avenue Gordon Smith, 7750 Colmar Berg, Grand Duchy of Luxembourg and registered with the Luxembourg Trade and Companies Register under number B 71.219] (hereafter also “Goodyear” or “we”) will process personal data about you (as further defined below). In that context, Goodyear will act as a controller, i.e. the person responsible for the processing of your personal data, as it decides why and how your personal data is processed.
The purpose of this Policy is to inform you and explain in all transparency:
why and how Goodyear collects, processes and stores your personal data;
what its role as “controller” of your personal data involves; and
what your rights and our obligations are in relation to this processing.
Definitions
For purposes of this Policy, the following definitions shall apply:
"personal data" means any information relating to an identified or identifiable natural person1;
"processing" shall mean any operation or set of operations that is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction and the verb “to process” shall be construed accordingly; and "processor" means a natural or legal person which processes personal data on behalf of the controller. Goodyear’s processors may be subsidiaries, affiliates or third-party suppliers and service providers. In all cases, Goodyear will conclude a data processing agreement with its processor to ensure your personal data is processed in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).
Categories of personal data collected
The types of personal data that are being processed depends on the role by which you are interacting with the Tool; there are three roles:
“Administrator”: someone managing User accounts, and/or at least having privileges for making content available for use by the User through the Tool, and generally monitoring usage statistics;
“User”: someone through the Tool i) interacting with the content being made available to him by the Administrator, and/or ii) making content available to a Third Party Data Subject for monitoring that Third Party Data Subject’s engagement with such content as well as its usage statistics;
“Third Party Data Subject” (usually the prospect / potential buyer), receiving specific information from the User through the Tool in respect of a potential business transaction to be negotiated/concluded with the User.
Each of these roles will generate their specific analytics as to the way how they interact with the content being made available through the Tool. Third Party Data Subject generated analytics will be visible to Users and Administrators; User generated analytics will be visible to Administrators. Where applicable to the Tool, Third Party Data Subject interactions with content occurring under “Kiosk Mode” will be attributed to and aggregated under the analytics of the User account setting up the “Kiosk Mode”.
We collect the following personal data; no sensitive personal data as per section 9 of the GDPR or (personal) financial data is being processed:
For each role (Administrator, User, Third Party Data Subject), certain contact information is being processed (i.e. direct identifiable personal data such as an e-mail addresses or name), as well as certain account information, profiling/behavioural information, device information, connection information, content, integrations with marketing automation/CRM services, geolocation (i.e. indirect identifiable personal data requiring a whole dataset in order to identify 1 single person).
In certain instances, certain video or other material (comments, reviews, …) that an Administrator, User or Third Party Data Subject may upload or provide to the Solution may also be processed.
For further specific information on which type of personal data are being processed, please contact the Showpad data protection officer at privacy@showpad.com.
Cookies and other similar technology
A cookie is a small text file that a website saves on your computer or mobile device when you visit a site. It enables the website to analyse your actions, to remember your preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
Web beacons are electronic images (also called “gifs”) that may be used in the Tool or in emails generated by the Tool that helps to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
More information on cookies and the and the way to refuse cookies can be found here. For more information per browser type see, Internet Explorer, Mozilla Firefox, Chrome, Safari.
For more information on Cookies used by Showpad, see the respective “Cookie Policy” section of the Showpad Privacy Policy
Security
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Goodyear takes appropriate precautions to protect personal data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, and to respond to the misuse, loss or unauthorized use of such personal data.
Information Goodyear collects may be stored on third party data storage systems (see section “Third-Party Recipients” below). In those instances, Goodyear also requires those third parties to employ security practices and systems to ensure the security of the information.
Purposes and legal basis of the processing
Purposes of the processing
Goodyear and processors acting on Goodyear's behalf use the personal data you give to Goodyear for the following purposes:
In respect of Administrators and Users:
account registration needed to use the Tool and management thereof (including checking the use you make of the Tool)
to allow you to share commercial Goodyear content with a (potential) customer (Third Party Data Subjects)
In respect of Third Party Data Subjects:
To share commercial Goodyear content with you and to check your consultation thereof
Legal basis of the processing
We are not allowed to process personal data if we do not have a valid legal ground. Therefore, we will only process personal data if:
we have obtained your prior consent; this legal basis is relied upon for the processing purposes mentioned above , including the use of cookies
for Administrators/Users: consent will be sought at the moment of creation of your account
for Third Party Data Subjects: consent will be sought at the moment of first interaction with the Tool or the content made available
additionally, certain personal data processing is based on the legal basis of the processing being necessary for the legitimate interests of Goodyear whereby this does not unduly affect your interests or fundamental rights and freedoms. The legitimate interest consisting of being necessary for technical reasons, (e.g. IP address is used to determine origin of the request resulting in certain privacy settings becoming applicable or not, e.g. email address of a (re-shared) Third Party Data Subject is used by Showpad for the technical aspects of delivering the message to the recipient under an SMTP protocol).Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interest and your privacy.
Third-party recipients
We transfer your personal data to Showpad, the provider of the Tool, to complete the purposes listed above, and to the extent they need it to carry out the instructions we have given to them.
For more information about how Showpad processes your personal data and with whom it shares such personal data, please check out the GDPR & Privacy Principles Showpad Product and in particular sections 16 to 18 thereof.
Your personal data may also be disclosed to:
any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and
any central or local government department and other statutory or public bodies.
Cross border data transfers
The personal data transferred within or outside Goodyear, may also be processed in a country outside the European Economic Area, which includes the EU Member States, Iceland, Liechtenstein and Norway (the "EEA").
If your personal data is transferred outside the EEA, we will enter into EU standard contractual clauses approved by the European Commission or ensure another safeguard allowed for by the GDPR is in place prior to such transfer to ensure the required level of protection for the transferred personal data. You may request additional information in this respect and obtain a copy of the relevant safeguard mentioned in article 46 put in place by exercising your rights as set out below (see section “Your rights”).
Data retention
The personal data will be permanently and irrevocably deleted after such periods as stated below.
– Data in Showpad hosted environment (production):
Administrator/User: From the moment the account is deleted by Goodyear or where the contract of Showpad with Goodyear is terminated, the account and the personal data is deleted, and the insights anonymised (deleted accounts can only be re-instated for up to 30 days after deletion after which deletion is irreversible). For avoidance of doubt, deactivation of an account does not by itself remove the account, the personal data or the insights; the account is only suspended.
Third Party Data Subject: As long as the respective Third Party Data Subject is interacting with or through the Tool and for a period of 24 months after the last interaction such Party has had with or through the Tool upon the lapse of which the account in Shared Spaces and the personal data is deleted, and the insights anonymised. If the respective Third Party Data Subject interacts again with the shared content, the counter resets.
Any action performed is sync’ed automatically and pretty much instantly in the production environment (including any deletions).
– Data in Showpad hosted environment (backup):
from a standard perspective, backups are done on a daily as well as weekly basis, and are kept:
Showpad Content: for up to three months following termination of the agreement with Goodyear, unless Goodyear so requests sooner. the personal data will be permanently and irrevocably deleted after such three month period.
Your rights
You have a right of access to your personal data as processed by Goodyear under this Policy. If you believe that any information we hold about you is incorrect or incomplete, you may also request the correction thereof. Goodyear will promptly correct any such information.
You also have the right to:
request the erasure of your personal data in certain cases;
request the restriction of the processing of your personal data in certain cases;
withdraw your consent where Goodyear obtained your consent to process personal data (without this withdrawal affecting the lawfulness of processing prior to the withdrawal); and
object to the processing of your personal data for other purposes in certain cases where Goodyear processes your personal data on another legal basis than your consent,
and Goodyear will honour such requests, withdrawal or objection as required under the applicable data protection rules.
In addition, you also have in certain cases the right to data portability. This is the right to obtain the personal data you have provided to Goodyear in a structured, commonly used and machine-readable format and to request the transmission of such personal data to a third party, without hindrance from Goodyear and subject to your own confidentiality obligations.
To exercise the above rights, please send an email to emea_data_privacy_team@goodyear.com, with a recto-verso scan/copy of your identity card or passport for identification purpose.
If you have any questions or are not satisfied with how Goodyear processes your personal data, please let us know by sending a message to Goodyear Dunlop Tires Operations S.A., avenue Gordon Smith, 7750 Colmar Berg, Grand Duchy of Luxembourg] or by e-mail at emea_data_privacy_team@goodyear.com. We will examine your question of complaint and get back to you as soon as possible.
You also always have the right to file a complaint with the competent data protection authority.
Showpad
The Tool that you are interacting with was created by the company Showpad. Showpad has drawn up an informational document about the privacy aspects of its products, including the Tool. Such document entitled the Showpad GDPR & Privacy Principles Showpad Product can be found here. Please have a look at this document if you want more information on how Showpad as a data processor processes your personal data via the Tool upon the instruction of Goodyear.
Updates to this Policy
Any future updates to the processing of your personal data as described in this Policy will be notified to you through the Tool (via a pop-up or otherwise) and/or through our other usual communication channels (e.g. by email, if available).
