Doosan Data Protection Policy
Doosan Robotics (“Doosan”, “we”, “our”, “us”) are committed to protecting and respecting your privacy. We are a Corporation established in the Republic of Korea with a registered office at 156-79, Saneop-ro, Gwonseon-gu, Suwon-si, Gyeonggi-do, Republic of Korea, 16648, 257-88-00128, and for the purpose of the General Data Protection Regulation (the “GDPR”), we are the data controller.
This data protection policy (hereinafter: “Privacy Policy”) governs the processing of your personal data as part of your visit to our website manual.doosanrobotics.com/help (hereinafter: “Website”).
NOTE 1: If you want information on how we process personal data via cookies, social plug-ins, pixels and other types of tracking technology, you are kindly referred to our Cookie Policy.
1. In general
1.1.
Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.
1.2.
Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
1.3.
Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy. In case of substantive or material changes such as a change in the processing purpose, a change to the identity of the controller; or a change as to how data subjects can exercise their rights in relation to the processing, we will inform you accordingly.
2. Types of personal data we process
2.1.
Whenever you use our Website, we collect:
Technical information associated with the device you use, such as your IP address, browser type, identifier and type of operating system;
your geographical location;
Information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.
2.2.
All of the personal data listed above, we receive directly from you. It may happen that we receive additional information about your preferences and surfing behaviour from partners in order to help us to improve the services we provide to you and the way the Website works. For more information please see our Cookie Policy.
3. Purposes for processing
3.1.
Doosan processes your personal data to provide you in only statistical analyses.
3.2.
Doosan processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
3.3.
Doosan may process your personal data for the preservation of the legitimate interests of Doosan, our partners or a third party if and when your use of the Website can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, Social Media Channels or other communication channels, (c) a danger to the Website, Social Media Channels or any of Doosan’s or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
4. Legal basis for processing your personal data
4.1.
For processing your personal data under the conditions outlined in clause 3.1, Doosan as the responsible party asks for your consent (Art. 6 (1) lit. a) GDPR).
4.2.
The processing of your personal data for the purposes outlined in clauses 3.1 is necessary to allow Doosan to comply with our legal obligations (Art. 6 (1) lit. c) GDPR).
4.3.
The processing of your personal data for the purposes outlined in clauses 3.1, 3.2 and 3.3 is based on Doosan’s legitimate interests (Art. 6 (1) lit. f) GDPR), which are:
Continuous improvements to Doosan’s Website to ensure that you have the best experience possible;
Keeping our Website safe from misuse and illegal activity;
Marketing and promotion of our products, services, brands an overall successful commercialization of our products and services.
5. Recipients
5.1.
We share your personal data to comply with law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities as well as financial institution in order to comply with our, or our partner’s, legal obligations as outlined in clauses 3.2, 3.3.
5.2.
Doosan does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers.
5.3.
Doosan relies on third party processors to provide you the Website as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of Doosan upon explicit written instruction of Doosan. Doosan warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.
5.4.
Doosan may share your personal data with Doosan Information & Communications, an affiliate of Doosan, for IT support and maintenance. However, we will ensure that all Doosan group entities will take due care that all processing of your personal data is in line with what is set out in this Privacy Policy.
5.5.
Notwithstanding transfers subject to clauses 5.1, 5.2 and 5.3, Doosan does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. Doosan may share your personal data in anonymized / pseudonymized form for analytical purposes, e.g., web logs collected on the Website.
6. Location and transfer
6.1.
Doosan stores and processes your personal data in the Republic of Korea. However, in order to process your personal data for the purposes outlined in clause 3 above, we may also transfer your personal data to other entities within the Doosan group or to third parties who process on our behalf. Such group entities or third-parties may also be located outside of the EEA. Nevertheless, we make sure that the necessary safeguards are in place to ensure an adequate level of data protection with respect to all processing activities outside of the EEA. Each entity outside of the EEA that processes your personal data shall be bound to observe adequate safeguards with regard to the processing such as:
a)
The Commission has decided that the recipient country in question ensures an adequate level of protection (so called adequacy decision pursuant to Art. 45 GDPR); orb)
A contractual arrangement between Doosan and that entity (e.g., EU Model Clauses pursuant to Art. 46 (2) lit. c and Art. 93 GDPR). All Doosan entities are parties to a contractual arrangement based on these EU Model Clauses (Commission Decision C(2004)5721).
6.2.
Doosan may transfer anonymised and/or aggregated data to organizations outside of the EEA. Should such transfer take place, Doosan will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to personal data you might enjoy under applicable mandatory law.
7. Quality assurance
7.1.
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
7.2.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
8. Data retention
8.1.
We will retain your personal data as follows:
Technical, behavioral and geographical data we collect whenever you use our Website and Social Media Channels pursuant to clause 2.1 will be stored for 12 months;
8.2.
Doosan will de-identify your personal data after expiry of the retention period outlined under clause 8.1 above, unless there is:
An overriding interest of Doosan, your financial institution, or any other third party in keeping your personal data identifiable; or
A legal or regulatory obligation or a judicial or administrative order that prevents Doosan from de-identifying them;
in which case the data will be stored until the overriding interest or legal / regulatory obligation no longer exists.
9. Your rights
9.1.
You have the right to request access to all personal data processed by Doosan pertaining to you. Doosan reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to Doosan.
9.2.
You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
9.3.
You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
9.4.
If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to marketing.robotics@doosan.com. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, Doosan may ask you for your signed confirmation and proof of identity.
Doosan will promptly inform you of having received this request. If the request proves valid, Doosan shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.
If you have any complaint regarding the processing of your personal data by Doosan, you may always contact Doosan via the e-mail address listed in this clause. If you remain unsatisfied with Doosan’s response, you are free to file a complaint with the competent data protection authority.
10. Withdrawal of consent
10.1.
Where you have provided your consent for us to process your personal data, you can withdraw your consent at any time by By refusing to accept cookies.
11. Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to marketing.robotics@doosan.com.