Acceptable Usage Policy

This Data Privacy explains how personal data about you is collected, processed and used by Girling (hereinafter “we,” or “us”) as data controller when you use the Girling Website available under girlingauto.com.

At Girling, we take our responsibility to protect your personal data serious. As used in this Data Privacy “personal data” means any information – either alone or in combination with other information we can access – that relates to you as an identified or identifiable individual. We respect your right to privacy and will only process your personal data in accordance with applicable data protection laws. This Data Privacy applies to information we collect when you use the Girling Website and its functionalities.

1. Information on Data Collection and Use

We collect certain information every time you visit our Girling Website. This information is used for the purposes which we list below. The specific types of personal data we collect depend upon your activities on the Girling Website, as also further explained below.

1.1. Information that is automatically collected

When you use the Girling Website without registration, you are not required to actively provide certain personal data; however, we automatically collect and process the following information:

technical session and connection information including IP address of your device; browser type; information about your device, hardware and software; preferences; web pages you visited just before the ZF Aftermarket Websites; pages you viewed on the Girling Website and dates and times of your visit.

We process and use the data specified above for the purposes of (1) providing the ZF Aftermarket Websites and its functionalities; (2) improving the Girling Website’s features and functionalities; and (3) preventing and detecting misuse and malfunction of the Girling Website including troubleshooting.

Collection of this type of information occurs inter alia by means of cookies. For more detailed information on the types of cookies and their specific purposes, please see Sec. 2 below.

The processing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the contract about the use of the Girling Websites; or (2) ZF has a legitimate interest in ensuring the functionality and error-free operation of the Girling Website and that it is tailored to the user’s needs.

1.2. Further services

You may provide further information to us when you order further services through the ZF Aftermarket Websites; such information may include: delivery address; payment information, etc. The collection and use of such additional information is governed by a separate Data Privacy for the particular service.

2. Cookies

We use cookies, a standard Internet technology that allows us to store and retrieve login and other usage information for every user of the Girling Website.

For more details regarding the usage of cookies visit Cookies.

3. Contact Forms, Subscription to Newsletters and other Marketing Communications

The Girling Website may offer you the possibility to subscribe to a newsletter or other marketing communications which will be sent to you via email. For this purpose we process and use your name and email address in order to provide you with the newsletter and other subscribed communications. The type of newsletter depends on the selection company type and vehicle type in the registration form.

The processing and use of personal data for the purpose of subscriptions to newsletters and other marketing communications is based on (1) statutory provisions which justify those operations on the ground that the processing is necessary for the performance of the subscription; or (2) your consent.We only use your details to provide you with the newsletter and other subscribed communications.

We use the double-opt-in-procedure in order to verify your subscription / consent. We store your confirmation in order to document and prove your subscription / consent. You have the right to cancel your subscription / to withdraw your consent or to object to the processing of your personal data for this purpose at any time without incurring any costs other than the transmission costs in accordance with the basic tariffs. The cancellation / withdrawal of consent shall not affect the lawfulness of processing based on consent before the cancellation / withdrawal. If you do that, we’ll update our records immediately to reflect your wishes.

We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters.

We use a service provider as our data processor to deliver the newsletters who may only process the personal data in accordance with our instructions and who is bound by a data processing agreement.

Google reCAPTCHA

Our website uses Google reCAPTCHA to check and prevent automated servers ("bots") from accessing and interacting with our website. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).

This service allows Google to determine from which website your request has been sent and from which IP address the reCAPTCHA input box has been used. In addition to your IP address, Google may collect other information necessary to provide and guarantee this service.

The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the security of our website and in the prevention of unwanted, automated access in the form of spam or similar.

Google offers detailed information at https://policies.google.com/privacy concerning the general handling of your user data.

4. Order of Brochures and further Promotional Materials

You can order brochures and – also in context of specific applications and services provided through the Girling Website - further promotional and advertising materials on our Girling Website. We process and use the information you provide (such as your name, address, further contact details as well as the selected brochure) to execute your order and send you the material in the desired manner (via email, postal service etc.).

The processing and use of personal data for these purposes is based on (1) statutory provisions which justify those operations on the ground that the processing is necessary for the performance of the orders; or (2) your consent. You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

5. Sharing Data within the ZF Group

ZF is a company located in Germany which operates globally and is part of the ZF group of companies, the current members of which are specified here [www.zf.com/locations] (“ZF Group”). The data you provide to us in the course of registration for a ZF Account (see no. 1.2 above), will be stored in our centralised customer data base and shared within the ZF Group for the purpose of managing your relationship with ZF and the ZF Group.

The sharing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the Agreement including the Terms of Use regarding the Girling Website; or (2) Girling has a legitimate interest in sharing this data within the ZF Group for internal administrative purposes.

Any transfer of your personal data to a third country (i. e. which is not a member of EU/EEA) will continue to be in compliance with all applicable data protection laws.

As far as a third country is not recognized by the European Commission to provide an adequate level of protection, Girling will take appropriate safeguards to ensure adequate protection of your data; e.g. by concluding data transfer agreements with third country recipients comprising standard contractual clauses which in accordance with the decisions of the European Commission provide adequate safeguards and can be requested under datenschutz@zf.com.

Sharing data outside of the ZF Group

In order to provide certain Applications and Services we share your data with particular external parties which perform services on our behalf. We may use third party service providers to offer or facilitate services on our behalf, such as a newsletter service provider, IT-provider, web hosting provider as well as any other service provider which act as data processors and therefore process the data on our behalf and under our instructions. These third parties are prohibited from using your personal data for their own commercial, promotional or any other purposes than those explicitly instructed for and they have to follow our express instructions and comply with appropriate security measures to protect your personal data.

We might disclose personal information when required by law to comply with a current judicial proceeding, a court order or legal process served on us, or as otherwise required by any applicable law, rule or regulation.

6. Detecting and Prosecute Misuse

We retain usage data including IP-addresses for the purpose of detecting and – as the case maybe – prosecuting misuse of the Girling Website. Unless required for prosecution purposes, the data will be deleted after 7 days. The retention and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the Agreement including the Terms of Use regarding the ZF Aftermarket Websites; or (2) Girling has a legitimate interest in ensuring the functionality and security of the Girling Website.

7. Deletion of Data

Generally, we delete personal data as soon as it is no longer necessary in relation to the purposes for which the data was initially collected or processed. In case the processing is based on consent and you withdraw your consent we will delete your personal data without undue delay after the withdrawal unless we are legally required to retain the data.

8. Other Services, Applications and Websites

Via the Girling Website you may access other services and applications the use of personal data by which is explained in separate date protection information documents. Also, our Girling Website contains links to other websites. Girling is not responsible for the use and protection of personal data on these other sites. We encourage you to be aware when you leave our Girling Website and to read the data protection information of the other websites.

9. Your Rights

You are generally entitled to request from Girling access to and rectification or erasure of personal data that we store about you or – as the case maybe - restriction of processing as far as it concerns you or to object to processing as well as the assert your right to data portability; all as granted by applicable data protection laws. You also have the right to lodge a complaint with a supervisory authority.

As far as you are entitled to further or modified rights beyond the rights set forth herein under applicable national law, these remain unaffected by the rights and claims set forth in this Data Protection Information. This also includes any claims for damages on the basis of a violation by Girling of the applicable data protection law as well as the right to provide us with guidance on the management of your data in the event of your death.

10. Contact

In case of any request concerning our use of your personal data or in case you want to assert any of your rights mentioned under Sec. 10, you may contact us by email online.zf-aftermarket@zf.com or by using our contact form which is accessible here.

The contact details of our data protection officer are as follows:

ZF Friedrichshafen AG
Data Protection Officer
Löwentaler Straße 20
88046 Friedrichshafen

11. Changes to this Data Protection Information

As our collection and processing of your data may change over time, we might also modify this Data Privacy in order for it to always correctly reflect our data processing practices. We encourage you to review it from time to time.