1. To whom does this data protection notice apply?

This is to inform you about the collection and processing of your personal data if you:

• Are interested in a bus or a test drive
• Have concluded a purchase contract for a new or used vehicle with us
• Have traded in a used vehicle with us
• Would like personal advice on products and divisions, vehicle models, services and offers or would like to make an appointment online for a personal meeting
• Have requested marketing material of any kind
• Have made a request of any kind on social media channels or by email
• Have concluded a service contract for a bus with us or your personal data is collected and processed in connection with this business relation, e.g. as an authorised representative, contact person
• Contact our 24 h service in the event of a breakdown
• Have concluded a service lease agreement with us
• Have concluded an OMNIplus ServiceCard contract with our partners
• Have entered into a contract with us via a service order or for after-sales services or your personal data is collected and processed in connection with this business relation, e.g. as an authorised representative, contact person
• Have concluded a contract with us by purchasing parts and accessories
• Use a short-term mobility solution, i.e. a vehicle (either a car or a bus, if applicable), for example while a customer vehicle is at one of our service sites for servicing
• Have concluded a warranty agreement with us
• Have contact with us as a contact person for suppliers, service providers and commercial customers

If you are the contact person of our contractual partner, of our prospective customer or for the enquiry, but are not actually our contractual partner, we will only process your contact data. If the enquiry is related to other services, their data protection notices shall also apply to these other services.

 

2. Where does my data come from, and what data is processed?

We process personal data ("data") in accordance with the basic principles of data avoidance and data frugality, only to the extent necessary, or to the extent it is permitted to us as a result of the applicable legal stipulations, or we are obligated to, or you have given your consent. Unless otherwise stated below, the terms "process" and "processing" include in particular the collection, use, disclosure and transfer of personal data (see Article 4, No. 2 GDPR).

Data in connection with your enquiry
In the context of your enquiry regarding

• a personal support and/or for a consultation
• of a vehicle as an interested party and in connection with inquiries of all kinds, e.g. from persons via social media channels and email, as well as online services, including the portals
• for sending marketing material

we collect data insofar as this is necessary for the fulfilment of our contractual obligations to you or you have consented to this. These include, in particular:

•  Master data of the prospective customer/interested party, in particular name or the user name you selected, date of birth if required
• Contact details of the prospective customer/interested party, in particular current address, telephone number and email address
• If necessary, vehicle data, e.g. licence plate number, desired model, vehicle data of the current vehicle of the prospective customer/interested party, in particular brand, year of manufacture, model, etc.
• The customer's interests in marketing activities, in particular events and the sending of advertising material
• Other data provided with the enquiry, if applicable

General data from the business relation (e.g. for the purchase of new and used vehicles and the trade-in of a used vehicle or for the purchase of parts and service contracts as well as in connection with warranty agreements and service orders)
We first collect, process and use the data that you provide to us as part of our business transaction or initiation of a contract. This includes in particular the following data:

• Master data of the customer(s) or contact person, in particular name and customer number as well as date and place of birth, nationality, interests, if applicable, number of your service card
• Contact details of the customer(s) or contact person, including address, telephone numbers and email addresses, fax number, if applicable
• Tax-relevant data of the customer(s) or the contact person, in particular VAT identification number, tax identification number, certificate in tax matters as well as data from the commercial register extract
• Insofar as authorised representatives are appointed: their master data, in particular name, date of birth and tax number, as well as contact data, such as addresses, telephone numbers and email addresses as well as interests
• Master data of guarantors, in particular name, date of birth, place of birth, nationality, marital status and tax number, as well as contact data of guarantors, such as addresses, telephone numbers and email addresses
• Contract data such as delivery, order and confirmation date, order number, start and end of contract, as well as warranty data, insurance number, (lease) instalment payments and repayment provisions, if applicable
• If necessary, bank details, such as IBAN and BIC, if you agree to a SEPA direct debit mandate
• Vehicle and fleet data, in particular manufacturer brand, vehicle identification number, licence plate number, as well as mileage, vehicle condition data (technical), vehicle history, as well as data for the main inspection, the (initial) registration and delivery and, if applicable, other data related to the respective business relation, e.g. vehicle owner, vehicle condition in the event of a breakdown, position data, engine identification number, workshop/repair logs, kilometre reading
• If necessary, other data such as job title, insofar as special conditions are granted by Daimler Buses UK Ltd with corresponding proof
• Annual financial statement documents or business analyses, company planning figures and other business and financial information
• Payment data ((booking data, payment history, loan data), in individual cases, a bank reference
• Income and financial situation in the context of self-disclosures, including proof of income
• Authentication data, in particular signature samples
• Data about your business activities and about potential business partners
• Data from a Secured Payment Certificate
• Data relating to administrative offences, data relating to criminal proceedings
• The data contained on the identity card or other identification documents presented
• Data related to after-sales service transactions, including invoice number, account code, dealer ID, information about products and parts or services sold
• If applicable, other data in connection with the fulfilment of the respective business relation

The following also applies to service work (maintenance, repair, etc.): Data from analysers
Under certain circumstances, we collect and process vehicle data and vehicle operating data (such as fuel consumption, speeds, requested engine torques, temperatures, braking torques) for the purpose of investigating and resolving complaints by an analyser which records the operation of the vehicle. This serves the fulfilment of the contract concluded with you or, in the case of personal data of vehicle drivers, the protection of the legitimate interests of Daimler Buses UK Ltd or a third party. In this context, additional data protection notices may apply, which you can find in your respective contract documents.

General data from business initiation/relationship with business partners

• Your master data, in particular name, gender, nationality and, if requested, organisation, function in the company and date of birth
• Your contact details, in particular address, telephone numbers and email addresses
• If necessary, other data relating to the fulfilment of the respective business relation of your client, such as dealer number, address data, contract data, bank details (IBAN, BIC, reference to SEPA direct debit mandate) and/or payment and booking data

As part of your enquiry, we also collect and process certain additional data that is necessary for the fulfilment of our contractual obligations to you. These include in particular:

• Data from correspondence (postal and electronic) between you and us
• Data from postal, electronic and telephone communication

Data from other sources
We also process personal data that we have received from, Daimler Buses UK Ltd, Daimler Truck AG Group companies and other affiliated companies of the Daimler Truck Group, as well as other third parties (e.g. credit agencies or service partners), insofar as this is necessary for the fulfilment of the contract concluded with you or pre-contractual measures or to protect our legitimate interests or you have consented to this. We process personal data from publicly accessible sources (e.g. Internet, newspapers) and public registers (such as the commercial register) only to the extent permitted by law, e.g. because this is necessary for the provision of our services or you have consented to this. We also receive data from authorities to fulfil our legal obligations (e.g. including but not limited to owner data from the German Federal Motor Transport Authority [Kraftfahrbundesamt KBA] and the DVSA in the event of product recalls).

 

3. What is my data used for (purpose of processing) and on what basis (legal basis) is this done?

Collection and processing on the basis of your consent
Your personal data will be collected and processed if you have expressly consented to this in advance (Article 6, Para. 1 a) GDPR).

If we do not already use your data for advertising purposes on the basis of our legitimate interest, we will obtain explicit declarations of consent from you.

In addition, from time to time we engage market research institutes in order to survey customer satisfaction and optimise our products and services in the interest of our customers. In this case we will also ask for your explicit consent.

Collection and processing in the context of the fulfilment of contractual and pre-contractual obligations
We collect and process your personal data as part of the initiation of a contractual relationship and for the fulfilment of our contractual and pre-contractual obligations to you (Article 6, Para. 1 b) GDPR).

For example, we process your personal data:

•  In order to be able to contact you personally as you requested or to be able to process your enquiry, e.g. via social media channels or by email
• In the context of contacting us for the processing and performance of a contract as well as for the proper fulfilment of our contractual and/or pre-contractual obligations
• In order to be able to send the requested marketing material
• To enable your test drive
• For you to purchase used vehicles
• For the purpose of organising and implementing breakdown assistance, including the associated processes
• To issue preferential certificates

To collect and process on account of statutory stipulations
In addition, we are subject to extensive legal requirements, for example pursuant to the Money Laundering Act or tax laws. The fulfilment of the resulting legal requirements requires the processing of your data (Article 6, Para. 1 c) GDPR).

Purposes for processing data include in particular

• Sanctions list checks, money laundering prevention and general compliance with legal requirements
• Compliance with legal requirements in the context of invoicing
• Compliance with statutory retention periods

Processing on the basis of a legitimate interest
In addition, we process your personal data insofar as this is necessary for the protection of the legitimate interests of Daimler Buses UK Ltd or a third party and does not override your interests or fundamental rights and freedoms that require the protection of personal data (Article 6, Para. 1 f) GDPR). "Third parties" shall refer to natural or legal persons, such as enterprises, public authorities, bodies, offices or other agencies. In this context, we as the responsible body and our contract processors are not "third parties" (cf. Article 4, No. 10 GDPR). This is particularly the case in the following cases:

• For fraud prevention purposes or sanction list checks (e.g. United Nations sanction lists)
• To ensure IT security and IT operations, hosting and other services, IT management and IT support
• In order to check your creditworthiness, e.g. in connection with service contracts, and on the basis of our interest in avoiding payment default or any risk of insolvency, we use a credit agency and, if necessary, a debt collection service provider to which we transmit the data concerning you necessary for this check and obtain information about your creditworthiness
• To conclude an insurance contract for the vehicle and to assert insurance claims
• For product monitoring and safety and legal consultation as well as for the assertion of legal claims and defence in legal disputes, including liability, which you or third parties assert against Daimler Buses UK Ltd or one of our affiliated companies
• To develop and improve products and services Analysis of product use/product properties, for quality assurance, e.g. during service work
• To prepare company financial statements and for accounting purposes
• In order to be able to provide support as quickly as possible in the event of a breakdown, to be able to process your queries, to be able to react in the sales consultation, to check invoices
• In individual cases for business, cost and risk management within the Group
• For communication processes such as internal communication and work processes
• To fulfil operational administrative purposes and to be able to optimise the products offered and to respond to the wishes and needs of our customers, e.g. as part of a telephone or electronic customer satisfaction survey. These surveys serve the permanent monitoring and improvement of our customer support quality and thus our competitiveness and customer orientation, which is why we assume a predominant legitimate interest on our part when processing your data
• For general market research as well as market-standard after-sales and business analytics evaluations, also on behalf of the respective dealers and national sales companies (where relevant), e.g. to determine how many products of a certain type were sold in a country or to validate price models
• To enable other, more specific business process-related analyses (e.g. to evaluate commission payments to individual dealers) and validate them or to support dealers and national sales companies (where relevant) with data analyses in one or more markets, e.g. to determine the age of a vehicle or a group of vehicles based on the chassis number

In addition, we use your data, in particular your contact data, for direct advertising by post about products as well as services and works and in individual cases also about special events. In addition, we use this information for promotional communications using our online services or by email, provided that we have received your email address in connection with the sale of products or the provision of services including work services, for advertising about our own similar products or services, including work services. If you object to the use of your data, we will no longer send you any advertising messages. When collecting your data and each time it is used, we will inform you clearly and unequivocally that you have the right to object to the use of your data at any time. We use this data to the extent described above for advertising purposes because we assume that we have a legitimate interest in the use of your data. We would like to send you information at regular intervals about our products and services that we think may be of interest to you

• To commission and support dealers and national sales companies (where relevant) in carrying out direct marketing campaigns on their behalf. Daimler Truck AG may also centrally manage and send corresponding marketing campaigns and materials to end customers in the name and on behalf of dealers and national sales companies (where relevant). All these activities are carried out exclusively on behalf of the aforementioned parties (data processing on behalf of a controller within the meaning of Article 28 GDPR).

We may also process your data anonymously for other processing purposes, e.g. for the further development of our services and products as well as for statistical purposes, analyses for business and cost management, as well as for the improvement of internal and sales processes.

 

4. Will my data be passed on?

We do not disclose your personal data to third parties unless you have consented to such disclosure, or we are entitled or obliged to disclose such data owing to legal provisions and/or official or court orders, or the passing on of data is necessary for the performance of the contractual relationship or to safeguard the legitimate interests of Daimler Buses UK Ltd or a third party. In this respect, we would like to point out the following data transfers:

Data transfer to order processors
For the provision of our services, we use processors (e.g. market research institutes, IT service providers and storage providers, call centre companies for the provision of our customer service or, for example, external debt collection companies for debt collection). Your data will be passed on to them by Daimler Buses UK Ltd in strict compliance with the obligation to maintain confidentiality and the requirements of UK GDPR, EU GDPR and the Federal Data Protection Act. The processing parties we commission, who may only process the data for us and not for their own purposes, are obliged to comply with strict standards defined by Daimler Truck Group.

Data transfer to authorised dealers, sales partners and subsidiaries of Daimler Buses UK Ltd as well as affiliated companies
We transmit your data, in particular your first and last name and your address, which we have received as part of a request for personal consultation, a vehicle or a (cooperation) request from persons via social media channels and by email, to authorised dealers and partners and/or branches and subsidiaries of Daimler Buses UK Ltd as well as affiliated companies of the Daimler Truck Group, which require the data to process your enquiry.

When you purchase a vehicle from us, we transmit your data, in particular your first and last name, your address, your customer number, the order number (if there is one), the vehicle purchase price and the vehicle identification number to our sales partners in the Territory (e.g. Setra general representatives), who will be contacted by you or involved by us within the framework of the handling of the vehicle transaction on account of their regional responsibility, so that we can provide you with better support. If you as a customer are based in a country outside Germany, we will transfer your above-mentioned data to the local sales partner responsible for you if necessary.

If you use a service product from us, we transmit your data, in particular your first and last name, your contact data, the contract data (contract type, contract term, etc.) and vehicle data (vehicle identification number, the date of the first registration of the vehicle you purchased, vehicle type and brand as well as the licence plate number, etc.) to our authorised service partners, who require them to perform your service orders. This is particularly the case in the context of warranty or goodwill claims/requests or for the execution of service and maintenance contracts for your vehicles and the provision of online services commissioned by you.

If we approve a credit for the Mercedes ServiceCard within the scope of the purchase contract, we will also send the data required to generate the credit for your purchase contract, invoice data, first and last name, customer account number, address data, the vehicle identification number, engine number, credit promotion number and credit amount to Mercedes ServiceCard GmbH & Co. KG regardless of the actual conclusion of a Mercedes ServiceCard.

For risk prevention purposes and to prepare the Daimler Buses Group balance sheet and that of Daimler Truck AG, certain master data from financing contracts with a residual value guarantee, in particular your name, your address, contract term, contract number and vehicle identification number will be shared with Daimler Truck AG. For the preparation of the balance sheets, certain receipt data such as, in particular, payment and booking data is also transmitted to Daimler Truck AG exclusively for these purposes.

Within the framework of the establishment and fulfilment of our contractual relationship with you, we store and process your data in IT systems, which are also used by the other companies affiliated to us. In this context, we use IT systems of the Daimler Truck Group that are shared with our subsidiaries, our authorised sales and service partners, Teleperformance Hellas, Daimler Truck AG and their subsidiaries. The aforementioned companies have technical access to the jointly used IT systems. Access to the data stored there is only granted insofar as this is necessary for the performance and processing of the business relationship with you, e.g. for the provision of maintenance, repair or other services connected with our products, as well as for ordering spare parts and in connection with the purchase of a vehicle.

Data transfer to suppliers
We transmit your data, in particular your first and last name, your address, the order number and customer account number, the vehicle identification number and the number of your contract, including suppliers (e.g. Daimler Truck AG and, if applicable, agents) that we have commissioned within the framework of a purchase contract and/or a service contract to manufacture and/or deliver equipment agreed with you and/or to deliver your vehicle and/or to provide certain services. Our suppliers use your data primarily to identify and assign the ordered equipment to your vehicle and/or to deliver your vehicle.

Data transfer to service providers
For the performance of service work, we use freight forwarding/towing companies/recovery companies, paint shops, vehicle preparation/automotive care companies, service providers for tyre storage, service providers for vehicle washing, rental vehicle providers. We transmit your data to this party, which is necessary for rendering the service. Furthermore, we also transfer your data, in particular your first and last name, your address to suppliers and/or logistics companies that we have commissioned to deliver parts and/or accessories ordered by you within the framework of a purchase contract.

If one or more optional service modules, e.g. maintenance, wear, “vehicle tax” or “fuel card management – factoring”, or one or more service modules, e.g. “tyre module”, “cooling unit protection” or “provision of replacement vehicle”, are included in your service contract, we will provide the customer data necessary for concluding and performing the corresponding service modules (e.g. address, telephone number), vehicle data (vehicle identification number, date of initial registration, vehicle type and brand, licence plate number and current kilometre reading, as well as, if applicable, the tyre size for “tyre module”; body type, body size and body serial number for “cooling unit protection”) and contract data (term of your contract, supporting workshop as specified in the service contract application) to the contract partner for the respective service module or the relevant body (e.g. petroleum companies).

Data transfer to authorities
As part of the purchase of a new and used vehicle, we transmit your data, in particular your identity card data, your vehicle registration document, the registration application, the TÜV certificate (certificate verifying roadworthiness) and, if applicable, your bank details to the responsible registration office or the German Federal Motor Transport Authority, insofar as the registration of your vehicle must be initiated by Daimler Buses GmbH at your request or this is necessary to process a recall.

If the VAT identification number is collected, we check its correctness with HMRC or the Federal Central Tax Office.

Forwarding of data to buyers
In the event of a sale of your vehicle to a third party, we must hand over the registration certificate Part II (vehicle registration document) containing your personal data to the third party.

Data transmission to insurance providers
We transmit your data that we have received as part of your service order or your purchase contract as a warranty holder – in particular your first and last name, the contract and vehicle data (contract type, contract term, vehicle identification number) - to the responsible insurance company, e.g. the motor vehicle insurer or its representative and, where applicable, a third-party company commissioned to broker the insurance contract for the conclusion of an insurance contract, in the event of changes to the contract and in the event of damage, insofar as this is necessary for the assumption of costs.

If you have concluded a guarantee package (e.g. BusStore guarantee) within the framework of a used vehicle purchase, the data necessary for the conclusion and execution of the corresponding guarantee contract, in particular your contact data, the duration of the BusStore guarantee, invoice amount, vehicle identification number, internal vehicle number, vehicle type and brand, licence plate (if known), delivery date, expiry date of the TÜV (German technical inspection association providing the certificate to verify roadworthiness) and the current kilometre reading will be transmitted to the partner of ours who shall be your contractual partner for the used vehicle guarantee.

Data transfer to experts
To ensure order and workshop quality, we employ external experts who must inspect service orders to carry out their work. Only the data that is absolutely necessary for the performance of the activity is transmitted.

Sharing data with credit institutions and payment service providers
Moreover, in the context of the performance of business relationships for products and services we also share your personal data with credit institutions and providers of payment services for invoicing and settlement of payments, provided you have given your consent or insofar as this is legally permissible.

Data transfer to credit agencies and debt collection agencies
Within the framework of our business relationship with you, we will share personal data collected on the application, execution and termination of our business relationship as well as data on conduct not in accordance with the contract, insofar as this is legally permissible.

 

5. Will my data be transferred to a third country or an international organisation?

As a matter of principle, we do not transfer data to countries outside the EU or the EEA (so-called third countries), unless we are obliged to do so due to official or court orders or in the cases mentioned below.

We also transfer your data to affiliated companies that may also be located outside the European Economic Area (EEA), e.g. Daimler Buses (Schweiz) AG, within the framework of the shared IT systems and for the proper fulfilment of our contractual and/or pre-contractual obligations. If there is no EU adequacy decision (according to Article 45 GDPR), we ensure that measures are taken by the affiliated companies so that the data is protected in the same way as in the EEA. The affiliated companies are bound by the strict data protection guidelines of Daimler Truck Group. Insofar as the recipients are not affiliated companies, but authorised dealers or distribution partners, we contractually ensure that measures are taken by the partners to ensure that the data is protected in the same way as in the EEA. The partners are also bound by the strict data protection requirements of Daimler Truck Group.

For the maintenance and support of IT systems, we also transfer data to service providers outside the EEA or authorise this access. As countries outside the EEA generally do not have an EU level of data protection, we contractually ensure that measures are taken by the service providers to ensure that the data is protected in the same way as in the EEA. The service providers are also bound by the strict data protection requirements of Daimler Truck Group.

For the purpose of organising and implementing breakdown assistance, including associated processes, personal data may be transferred to third countries on the basis of Article 49, Para. 1 b) GDPR (depending on the location of the vehicle).

 

6. Does automated decision-making take place?

In principle, no automated decision-making takes place within the meaning of Article 22 GDPR.

 

7. For how long will my data be stored?

The exact retention period depends on the purpose for which the personal data is processed. Daimler Buses UK Ltd generally uses the following criteria for the retention of personal data:

• Personal data is stored for as long as necessary to achieve the purpose for which it was collected.
• Erasure always takes place in accordance with the relevant legal and regulatory requirements.
• The periods for the fulfilment of commercial and/or tax retention obligations are 6 or 10 years, respectively, in accordance with statutory provision. For this reason, we keep invoice documents for this length of time.
• We will store your personal data for advertising purposes, i.e. the sending of information and offers about products and services, for a maximum period of six years from the last relevant contact with you - provided there is no active business relationship with you. A relevant contact exists, for example, if there is verbal, telephone or mutual written communication between you and us.
• For personal data relating to a contract you (or the company you work for) have entered into with us, the retention period is the duration of this contract plus the limitation period for claims arising from this contract, unless mandatory legal or regulatory requirements require a longer or shorter retention period.
• If there is no longer a legal basis for the processing, your personal data will be deleted or anonymised immediately.