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, Webshops and Social Media Channels, 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.
  When you fill out the contact form on our Website, or contact us via e-mail, telephone, fax or Social Media Channels, we collect:

  • The basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function;
  • The content of your communication and the technical details of the communication itself , such as with whom you correspond at our end, and the date and time;
  • Publicly available information of your profile on Social Media Channels;
  • Any other personal data you choose to provide to us.
• 2.3.
  When you place an order on one of our Webshops, as customer or supplier, we collect:

  • The basic identity information we require to process your order, such as your name, company, function, postal address and telephone number;
  • Details pertaining to the order itself;
  • Your payment details.
• 2.4.
  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 a personalised and efficient way with the information, products and services you request via the Website, e-mail, telephone, fax, Social Media Channels and Webshops. Also, in case you make a purchase via our Webshop, we also collect your payment details.
• 3.2.
  Doosan processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Doosan and selected partners.
• 3.3.
  Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, Doosan will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.
• 3.4.
  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.
  Your personal data may be transferred upon Doosan’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, Webshops, our Social Media Channels or other communication with us.
• 3.5.
  Doosan may be required to collect and transfer your personal data to our financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.
• 3.6.
  Doosan processes your personal data to perform statistical analyses so that we may improve our Website, Webshops, products and services or develop new products and services.
• 3.7.
  Doosan may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.
• 3.8.
  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 registration with or use of the Website, Webshops, Social Media Channels or other communication channels 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, Webshops, Social Media Channels or other communication channels, (c) a danger to the Website, Webshops, Social Media Channels or other communication 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 3.3, Doosan as the responsible party asks for your consent (Art. 6 (1) lit. a) GDPR).
• 4.2.
  The processing of your personal data including your payment details for the purpose of fulfilling an order you have placed via one of our Webshops is necessary for performing the agreement between you and Doosan (Art. 6 (1) lit. b) GDPR).
• 4.3.
  The processing of your personal data for the purposes outlined in clauses 3.4 and 3.5 is necessary to allow Doosan to comply with our legal obligations (Art. 6 (1) lit. c) GDPR).
• 4.4.
  The processing of your personal data for the purposes outlined in clauses 3.1, 3.6, 3.7 and 3.8 is based on Doosan’s legitimate interests (Art. 6 (1) lit. f) GDPR), which are:

  • Continuous improvements to Doosan’s Website, Webshops, Social Media Channels, products and services to ensure that you have the best experience possible;
  • Keeping our Website, Webshops, Social Media Channels, products and services 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 or payment service provider in order to comply with our, or our partner’s, legal obligations as outlined in clauses 3.4, 3.5 or 3.8.
• 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 and Webshops 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); or
  • b)
    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.
• 7.3.
  If you are registered to receive communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels, you can change your preferences for receiving such communications, promotions, offerings, newsletters and other advertisements by sending a request to marketing.robotics@doosan.com.

8. Data retention

• 8.1.
  We will retain your personal data as follows:

  • a)
    Technical, behavioral and geographical data we collect whenever you use our Website, Webshops and Social Media Channels pursuant to clause 2.1 will be stored for 12 months;
  • b)
    Data we collect by way of our contact form pursuant to clause 2.2 for 12 months;
  • c)
    Order data pursuant to clause 2.3 for as long as necessary in order to perform the contract. However, certain data such as your basic identity information we require to process your order, the details pertaining to the order itself and your payment details will be retained for 10 years for tax law purposes.
• 8.2.
  Besides that, we will immediately delete your personal data when you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website, Webshops, Social Media Channels and other communication channels.
• 8.3.
  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, the payment service provider, 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 ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.
• 9.3.
  You have the right to withdraw your earlier given consent for processing your personal data, in which case clause 8.2 will apply.
• 9.4.
  You have the right to request that personal data pertaining to you be deleted if they are no longer required in light of the purposes outlined in clause 3 or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by Doosan against:

  • Overriding interests of the Doosan, your financial institution, the payment service provider or any other third party;
  • Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

  Instead of deletion you can also ask that Doosan limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes listed under clause 3 but you need them to defend yourself in judicial proceedings.

• 9.5.
  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.
• 9.6.
  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.
• 9.7.
  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 email to marketing.robotics@doosan.com.

11. Objection to marketing

• 11.1.
  At any time you have the right to object to our processing of data about you in order to send you marketing and we will stop processing the data for that purpose.

12. Contact

• Questions, comments and requests regarding this policy are welcomed and should be addressed to marketing.robotics@doosan.com.