We take your privacy seriously, and we want you to know how we collect, use, share, and protect your information. “Webasto” means any entity that carries the Webasto brand, and any of our subsidiaries or divisions
What Personal Data Do We Receive?
Personal data is any information from or about an identified or identifiable person, including information that Webasto Thermo & Comfort North America, Inc., (“Webasto”) can associate with an individual person. Webasto may collect, or process on behalf of its customers, the following categories of personal data when you use or interact with Webasto Products:
- Profile and Account Information: Information associated with the profile of a user who uses Webasto Products under a licensed account, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user or their
- Settings: Information associated with the preferences and settings on a Webasto account or user
- Registration Information: Information people provide when registering for a mobile application, which may include name and contact information, responses to registration questions, and other registration information requested by the host.
- Device Information: Information about the phones, and other devices people use when interacting with Webasto Products, which may include information about the device attributes (like operating system version and battery level), WiFi information, names of devices and other device information (like Bluetooth signals). The app does not collect or store the user’s phone location but location permission is requested to allow the app to scan Bluetooth.
- Product Usage: Information about how people and their devices interact with Webasto
- Communications with Webasto: Information about your communications with Webasto, including relating to support questions, your account, and other inquiries.
How Do We Use Personal Data?
Webasto does not sell, rent, or trade your personal information to third parties. We share your information only in the ways we describe below. We may combine or share information among current or future Webasto companies, including affiliates and subsidiaries. Webasto employees do not access Customer information unless directed by an account owner, or as required for legal, safety, or security reasons, as discussed below. Webasto uses personal data to conduct the following activities:
- We use information about you to fulfill your requests, administer various programs, provide services, and for other business purposes.
- Your personal information may be shared with current or future Webasto entities or
- We may also use the information you provide to send you marketing
- In some circumstances, Webasto may share your information with certain third parties to perform services on our behalf.
- To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.
How Do We Share Personal Data?
Webasto provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):
- Phone Information: The name of a user’s phone will be used to implement Webasto’s allowed devices policy. The Android permission "ACCESS_FINE_LOCATION" is a requirement of Bluetooth operations on Android devices.
- Vendors: Webasto works with third-party service providers to provide, support, and improve Webasto Products and technical infrastructure, and for business services such as payment Webasto may also work with third-party service providers to provide advertisements and business analytics regarding Webasto Products. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Webasto or as required by law.
- For Legal Reasons: Webasto may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
- Marketing, Advertising, and Analytics Partners: Webasto may use third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using Webasto Products; to provide advertising and marketing for Webasto Products, including targeted advertising based on usage; and to show you third-party advertising within Webasto Products. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available Cookies Settings. Where required by law, Webasto will first obtain your consent before engaging in the marketing or advertising activities described.
- Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Webasto’s business or assets, including in connection with bankruptcy or similar proceedings.
Privacy Rights and Choices
If you are a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:
- Inform you of what personal data we have about you that is under our control;
- Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
- Delete such personal data or direct you to applicable
- Webasto does not knowingly collect information through its Smart Temp 0 app from children under 13.
How to Contact Us
You can also contact us by writing to the following address:
Webasto Thermo & Comfort North America, Inc.
15083 North Road
Fenton, MI 48430, U.S.A
The criteria used to determine our retention periods include the following:
- The length of time we have an ongoing relationship with you and provide Webasto Products to you (for example, for as long as you have an account with us or keep using our Products);
- Whether account owners modify or delete information through their accounts;
- Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).
California Privacy Rights
California Consumer Privacy Act
Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:
- Access the categories and specific pieces of personal data Webasto has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Webasto has shared personal data;
- Delete personal data under certain circumstances; and
- Opt out of the “sale” of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. The CCPA’s statutory definition of the term “sale” is broad and may include interest-based advertising.
Webasto will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.
Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Webasto app account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
Changes to This Privacy Statement
We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our Products.