Activity Manager Privacy Policy (App)

1. Introduction

We, MSX International UK Limited a company incorporated under the Companies Act, 1956 and having its registered office at the Octagon, Colchester. (hereinafter referred to as “MSX” or the “Supplier” or “Receiving Party” or “Company” or “we” or “our” or “us”) offer our services to individuals and organizations (“Members”) in the field of automotive retail to offer their expertise and experience to other Members or users (“Services”) with the use of proprietary mobile applications or web portals. Activity Manager, henceforth known as “Activity Manager” – is one such mobile application developed by us. References to "you", “users”, “your” shall mean the users accessing and using the Services of Activity Manager. We respect the privacy of our users and beneficiaries of our Services and the Activity Manager. This privacy policy (“Privacy Policy”) describes the procedures for collecting, using, and disclosing your information which you may share with us for using, availing or accessing the Services of the Activity Manager (“Personal Information”). We urge you to read this privacy policy carefully so that you understand our approach towards the use of your Personal Information. By agreeing to avail the Services or using Activity Manager, you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

2. Governing Law

This Privacy Policy is fundamentally based upon the European Union’s General Data Protection Regulations, one of the world’s most comprehensive legal frameworks, that sets guidelines for the collection and processing of personal information from individuals. Where Activity Manager is operated outside of the Union, we will abide by local data protection laws; whichever provides greater levels of protection to our users.

3. An overview of data protection

General

The following gives a simple overview of what happens to your personal information when you use Activity Manager. Personal information is any data with which you could be personally identified. Detailed information on the subject of data protection can be found in our privacy policy found below.

Data collection on Activity Manager

Who is responsible for the data collection on Activity Manager?

The data collected on Activity Manager is processed by the application Controller, MSX International Inc. The Controller's contact details can be found in the MSX-required legal notice.

How do we collect your data?

Some data is collected when you provide it to us. This could, for example, be data you enter in a registration form. Other data are collected automatically by our IT systems when you use Activity Manager. This data includes your performance within Activity Manager as well as technical data such as the device or operating system you are using or when you accessed the page. This data is collected automatically as soon as you enter Activity Manager.

What do we use your data for?

Part of the data is collected to ensure the proper functioning of Activity Manager. Other data can be used to analyze how visitors use the technology.

As an example:

Monitor user activity and usage trends, such as keyword searches, time related statistics including time spent using the app and engaging with particular pieces of content.
Create and manage user accounts;
End user support;
Manage our relationship with you;
Monitor suspected fraud, misconducts and unlawful activities occurring on/through Activity Manager.

You agree that we may also use the Personal Information to contact you and deliver information to you that, in some cases, are targeted to your interests, such as targeted Member communications, Member requests, Member offerings, and other communications relevant to your use of Activity Manager. By accepting this Privacy Policy, you expressly agree to receive this information.

What rights do you have regarding your data?

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice or at privacy@msxi.com if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.

However, any inability for us to process your data, in accordance with this policy and your requests to block or delete its use, might prevent us from being able to offer you access to Activity Manager.

Analytics and third-party tools

When using Activity Manager, statistical analysis will be made from your usage behavior. This happens primarily using analytics. The personally identifiable analysis of your behavior is pertinent only to the usage of Activity Manager in terms of your timed engagement with Activity Manager and its various content. All other possible analysis will be completed at an anonymous level.

You can object to this analysis or prevent it by not using Activity Manager. Detailed information can be found in the following privacy policy.

Activity Manager uses Google Analytics for this service. Read the Google Privacy Policy for more.

You can object to this analysis. We will inform you below about how to exercise your options in this regard.

What rights do you have regarding your data?

Aside from third party tools used to process data or present media, the Activity Manager Application can be managed on behalf or by our customer, your Manufacturer Brand’s Company. As such, Data relevant to their ability to manage the services they offer you through Activity Manager, will be shared. This will be limited by the level of service they manage. For instance, if MSX International are responsible for the development and dissemination of content through Activity Manager on behalf of our customer, the customer access would likely be limited to anonymized performance reporting. If however, the customer vehicle brand is responsible for managing the content dissemination through Activity Manager, their access to your data would be appropriately and proportionally increased.

We may also engage third party companies or individuals to process other information and support MSX International in delivering our service for you.

In both cases, we will ensure that any third party accessing your data will comply with this Policy and any applicable laws.

Links to Third Party Websites

Activity Manager may contain links to third party websites, plug-ins and applications. Accessing these links may allow third parties to collect or share data about you. Where MSX International does not control or own these technologies, you will no longer be covered by this policy. We would advise you to access the policies of these sites and ensure you are informed as to your rights.

4. General information and mandatory information

Analytics and third-party tools

The Controller of Activity Manager takes the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy.

If you use Activity Manager, various pieces of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens.

Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.

Notice concerning the party responsible for this Activity Manager

The party responsible for processing data on this CMS is:

MSX International Inc.
The Octagon,
Middleborough,
Colchester, C01 1TG | UNITED KINGDOM

Phone: +44 (0) 1206 202000
Fax: +44 (0) 1206 767 615
Mail: privacy@msxi.com

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

Revocation of your consent to the processing of your data

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email to productmarketing@msxi-euro.com making this request is sufficient. The data processed before we receive your request may still be legally processed.

Right to file complaints with regulatory authorities

If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the data protection officer of the German state in which our European division company is headquartered. A list of data protection officers and their contact details can be found at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Right to data portability

You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

SSL and TLS encryption

Activity Manager uses SSL and TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the technology operator. When SSL and TLS encryption is activated, the data you transfer to us cannot be read by third parties.

Information blocking, deletion

As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient, and the purpose for which it has been processed. You also have the right to have this data corrected, blocked, or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.

Opposition to promotional emails

We hereby expressly prohibit the use of contact data published in the context of Activity Manager legal notice requirements with regard to sending promotional and informational materials not expressly requested. The Activity Manager Controller reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.

5. Data protection officer

Statutory data protection officer

We have appointed a data protection officer for our company.

Datenschutzbeauftragter der MSX
MSX International GmbH
Hugo-Eckener-Str. 20
50829 Köln

E-Mail: Datenschutz@msxi-euro.com

6. Data collection on Activity Manager

Local Storage

Activity Manager uses “local storage”, which is a file or files stored on your device, to save your name and username, authentication token and anonymous application configuration and settings between visits to or launches of Activity Manager. You can erase this from your device by deleting the Activity Manager application. This data is only used to allow Activity Manager to work as expected and is necessary for it to function, it is not shared with any third parties. Local storage used by the Activity Manager can only be accessed by the application.

Server log files

The Activity Manager Controller automatically collects and stores information that your device automatically transmits to us in "server log files". These are:

Device type and version
Operating system used
Host name of the accessing device
Time of the server request
IP address of the accessing computer
User's device screen width and height
Which language the user requested a response in
The address the request was for
The version of Activity Manager the user has used

This data will not be combined with data from other sources.

The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract, or for measures preliminary to a contract.

Data Residency

In an effort to maximise performance of Activity Manager and your user experience, we host your data in a cloud-based server based within an appropriate region to best service your needs. As such, the Personal Information that we collect from you may be stored and processed outside of your local country. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located. In the event that we may transfer your Personal Information to other countries to improve performance of Activity Manager, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third-party service providers provide an adequate level of protection to your Personal Information. We would only transfer your Personal Information in accordance with applicable laws or where you have given us your consent to do so.

7. Changes to this Policy

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use your Personal Information, we will post these changes on this page and it shall be your responsibility to be aware of any significant changes. Please check our Privacy Policy on a regular basis.

This Privacy Policy was last modified on 25th December 2019.