>Mercedes-Benz Group Data Protection Code of Conduct
Collection and Processing of Personal Data
When you visit our website, our web server automatically records the name of your internet domain, internet service provider, browser and operating system used to access our website, the website from which you visit us, the web pages you actually visit and the date and length of your visit. This information allows us to measure site and user activity to tailor information to suit your individual preferences. We will take all practicable steps to ensure that your personal data is not kept longer than is necessary for the fulfillment of the purposes (including any directly related purposes) for which the data is to be used.
Personal data (for example your name, gender, age, email address, mailing address, telephone number, residency, nationality, company and job position) is only stored if volunteered by you, for example when you register with us, request for customer service or other assistance, submit a customer survey, enter into a contest or a contract through this website and/or through events organized by MBHK, or by MBHK in cooperation with Zung Fu Company Limited (“ZF Hong Kong”), Zung Fu Motors (Macau) Limited (“ZF Macau”) and Mercedes-Benz Financial Services Hong Kong Limited (“MBFS”) and/or other third party host or co-host of events/workshops. You should be aware that when you voluntarily disclose personal information in public areas of our website, such as bulletin boards, this information may be seen and used by others. We urge you to exercise good judgment when sharing personal information in these forums.
Technically Required Required web technologies and cookies make our website technically accessible to and usable for you. This applies to fundamental base functionalities such as navigation on the website, correct display in your internet browser or your consent request. Without these web technologies and cookies our website will not function properly. Analysis and Statistics We want to constantly improve the user-friendliness and performance of our websites. For this reason we use analysis technologies (including cookies) which pseudonymously measure and evaluate which functions and content of our websites are used, and how and how often they are used. On this basis we can improve our websites for users. Comfort We want to improve the user-friendliness of our websites for you. For this reason we use web technologies (also cookies) in order to store settings selected by you and to show selected content on the basis of your usage behaviour. Marketing We use web technologies (also cookies) from selected partners in order to be able to show you content and advertising specially tailored to you on websites and social media sites. This content is selected and displayed on the basis of your usage behaviour.
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 website. Further, our website settings allow you to deactivate the use of certain categories of cookies. However, it is possible that some parts of the website will not function properly if you modify your browser or website settings. Further, we may not be able to recognize you as a visitor over time.
Use and Disclosure of Personal Data and Purpose Specification
We will use your personal data for the following purposes only to the extent necessary in each specific case:-
• Carrying out the purposes for which such information was provided (including but not limited to responding to your questions, inquiries or concerns, and providing you with the relevant product, service or support); • Technical administration of the website such as monitoring or improving the use of the website and performing cookie data analysis which assists in search engine optimization; • Customer administration of the website such as communicating with you about changes to our policies; • Administering and inviting you to participate in our product surveys; • For direct marketing and promotional events (including test drives) organized by us and/or our exclusive authorised dealers in Hong Kong and Macau, ZF Hong Kong and ZF Macau respectively and/or by MBFS and/or by other third party host or co-host of events/workshops (including without limitation, advising, promoting, marketing and informing you about our automobile and related financial products and services and activities and events in connection therewith) or for promotion on or invitation to events/workshops hosted by us or other third party companies or co-hosted by us and other companies on automobile or non-automobile related products and services. Please refer to the section “Freedom of Choice” below for further information; • Detecting, investigating and preventing activities that may violate our policies or be illegal, or for compliance with any applicable laws and regulations.
Apart from the above, we shall not share your personal data with any third parties except as follows:-
We will transfer your personal data to our agencies, service providers, suppliers and data processors only on a need basis and only personal data strictly required by them to perform their functions will be transferred. We have adopted adequate contractual and other means to (i) prevent unauthorized or accidental access, processing, erasure, loss or use of your data and (ii) prevent any personal data from being kept longer that is necessary.
Our employees, agencies, ZF Hong Kong, ZF Macau and MBFS and other third party host or co-host of events/workshops 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. Subject to applicable laws, we 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 website or any information you transmitted to this website.
Freedom of Choice
We should like to use your data, and share your data with ZF Hong Kong, ZF Macau and/or MBFS and/or other third party host or co-host of events/workshops, to inform you and market our automobile, related financial products and services and activities and events (including test drives and other promotional events organized by MBHK, Mercedes-Benz Group, ZF Hong Kong, ZF Macau and/or MBFS) or for promotion on or invitation to events/workshops hosted by us or other third party companies or co-hosted by us and other companies on automobile or non-automobile related products and services and where applicable request your opinion. Naturally your participation is completely voluntary, and we may not so use your personal data unless we have received your consent (which includes an indication of no objection) or unless otherwise permitted under the PDPO and/or the guidance notes or directions of the Privacy Commissioner for Personal Data.
If you consent to our use of your personal data for direct marketing and promotional purposes, please tick the relevant box in the form by which your personal data is collected.
In any event, you can also inform us at any time that you wish us, and/or the companies mentioned herein to cease using your personal data for direct marketing and promotional purposes. Such notification should be sent to the responsible personnel whose contact details are set out in the section headed “Freedom of Information” below.
In accordance with the PDPO, we have put into place reasonable safeguards and precautions such as the use of technical and organisational security measures to protect the data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons. Our security procedures are continually enhanced as new technology becomes available.
However, while we try our best to safeguard your personal data once we receive it, no transmission of data over the internet or any other public network can be guaranteed to be 100% secure.
Freedom of Information
Upon request, we (or our representatives) will, subject to an administrative fee payable by you, inform you without delay in writing as defined by the applicable law what personal data is stored by us.
You may also at any time request access to and correct your personal data held by us (or those held by ZF Hong Kong, ZF Macau as our exclusive authorized dealer in Hong Kong or Macau respectively, or by MBFS). If you wish to do so, please contact the following personnel whose contact details are as follows:-
Zung Fu House, 60 Ka Yip Street, Chai Wan, Hong Kong Email: firstname.lastname@example.org Telephone: (852) 2895 7330 Contact: Customer Relations
Should you have questions regarding the processing of your personal data you can also refer to our chief corporate data protection officer, who is also available with his team for enquiries, suggestions or complaints. The contact details of our chief corporate data protection officer is set out below:
Data Protection Officer: Mercedes-Benz Group AG Chief Officer Corporate Data Protection HPC E600 70546 Stuttgart Germany E-mail: email@example.com