The meaning of Personal Data
“Personal Data" is defined in data protection laws applicable in your country. It includes any information relating to an identified or identifiable natural person.
Important notice about international transfers from the EU to non-EU countries
Due to the global nature of our business, your Personal Data may be stored and transferred to parties located in other countries, including outside the European Economic Area. These countries may have different data protection laws than your country of residence and may not be deemed by the European Commission as providing adequate protection for Personal Data.
The categories of Personal Data we may collect, the purpose and the lawful basis
Personal Data collected from you include the following:
|Categories of Personal Data||Purpose||Lawful Basis|
Application data (e.g. name,
|Processing of this personal data is required to enable Horizon to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews||Processing is necessary for us to entering into a contract with you.|
Contact information (e.g. full name, postal address, e-mail address, employer/business and professional information, job titles, telephone and fax numbers)
|Managing and responding to your queries.||Legitimate interests – it is important that we can respond to your enquiries|
|Contact information (e.g. full name, postal address, e-mail address, payment details)||Processing orders submitted via our online shop. Setting up your account to grant you access to information, news and our business relationship.||Performance of contract|
Browsing information (IP address, browser information)
|Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality.||Legitimate interests - we need to perform this limited routine monitoring to make sure our Sites work properly, to diagnose any problems with our server and administer our Site.|
|E-Mail address, name||We use this data to send you newsletters and marketing information.||Your consent|
|All information||Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity Complying with instructions from law enforcement agencies, any court or otherwise as required by law For our general record-keeping and customer relationship management Managing the proposed sale, restructuring or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation Resolving any complaints from or disputes with you||Legitimate interest (see column on left)|
In summary, we need certain categories of Personal Data because it is necessary to administer any contract with you (where relevant). Certain other Personal Data is processed for our legitimate interests in cases where this does not result in prejudice to you.
Keeping you informed and direct marketing
With your consent, where relevant we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our own related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone, fax or email for this. If at any time you decide that you do not want your contact details used for these purposes, please tell us through using the “unsubscribe" function on the correspondence or contact us (see “ Contact us" below).
Cookies and analytic tools
You can disable cookies using your Internet browser settings. Please consult your browser's help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Site may not function properly.
Horizon uses Google Analytics on the Websites with the extension “anonymizeIP()", IP addresses being truncated before further processing in order to rule out direct associations to persons.
Disclosure of your Personal Data to third parties
We may disclose your Personal Data to third parties, including but not limited to as follows:
2. to third parties who supply services to us and who help us and our group of companies to operate our business. For example, sometimes a third party may have access to your Personal Data in order to support our information technology or to handle mailings on our behalf (e.g. Rackspace, MailChimp, Inxmail);
3. to our legal and other professional advisers;
4. as necessary in order to comply with a legal requirement (including, where appropriate, any imposed on our group companies in the United States), for the administration of justice, to protect vital interests, to protect the security or integrity of our databases or this Site, to take precautions against legal liability; and
5. to regulatory authorities, courts and governmental agencies to comply with legal orders, legal or regulatory requirements and government requests.
Security of Personal Data
We endeavor to use appropriate technical and physical security measures to protect Personal Data which is transmitted, stored or otherwise processed by us, from an unlawful destruction, loss, alteration, unauthorized disclosure of, or access, in connection with our Site. These measures include computer safeguards and secured files and facilities. Our service providers are also selected carefully and required to use appropriate protective measures. In certain areas, Horizon uses industry-standard SSL-encryption to protect data transmissions. Most current browsers support the level of security needed to use these areas.
In particular, we endeavor to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymization (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Data, (c) ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and (d) ensuring a process for regular testing, assessing and evaluating the effectiveness of technical and organizational security measures.
Retention period or criteria used to determine the retention period
We keep your Personal Data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above.
The criteria we use to determine data retention periods for Personal Data includes the following: (i) Retention according to our Global Records Management Policy and
corresponding schedules; and (ii) Retention in accordance with legal and regulatory requirements.
If your application for employment is successful and you commence employment with Horizon, your Personal Data will be transferred to your personnel file and will be processed for employment purposes. If your application for employment is not successful, we will keep your Personal Data in accordance with our Global Records Management Policy and corresponding schedules for a period of six (6) months upon notification that your application was not successful.
Your rights under data privacy laws
You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Data we hold about you; the right to rectification including to require us to correct inaccurate Personal Data; the right to request restriction of processing concerning you or to object to processing of your Personal Data, the right to request the erasure of your Personal Data where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Data in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent. You can also lodge a complaint with a supervisory authority.
Please see “Contact Us" if you wish to exercise any of these rights (as relevant).
Links to Other Websites
If you wish to exercise your data protection rights, please e-mail [email protected].
|Alternatively, write to:||For persons in the EU, write to:|
Attn: Data Protection Notice Horizon Global Corporation
2600 West Big Beaver Rd., Ste. 555
Troy, Michigan 48084
Phone: +1 (248) 593-8820
Attn: Data Protection Notice Horizon Global Corporation
Prins Bernhardplein 200
1097 JB Amsterdam
We have appointed a data protection officer for our companies in Germany. Please write to [email protected] for further information and requests.
Last updated: 25 May 2018