Privacy Policy
Toyota Automated Logistics
Data Privacy Notice
We (meaning the specific company that has provided or referred you to this privacy statement or that is identified on this page as being the operator of this website) believe that protecting the security and privacy of your personal data is important. This Privacy Statement explains how we collect, store, use, disclose and transfer (hereinafter "process") your personal data and how we collect it both online when visiting our external and internal websites or using our applications, online services, or marketplaces (“Online Offering”), offline, and when you apply for employment with Toyota. The personal data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and applicable law.
1. Processing of personal data
The types of personal data we obtain about you depends on how you interact with us and use our services (including the Online Offering). In the past twelve (12) months, we have collected the following categories of personal data for the following purposes:
1.1. Categories of personal data:
- Contact information (e.g., full name, work address, work telephone number, work mobile phone number, work email address)
- Organizational information (e.g., job position/title, company name, and similar business affiliation details)
- Account, interaction, and communications information (e.g., information you submit through forms; account administration details; content of inquiries, support requests, surveys, comments, forum posts, or other communications with us)
- Transaction, billing, and payment information (e.g., order details; invoices; payment status; and where applicable, payment card information and related billing details necessary to process payments and help prevent fraud)
- Order/project and relationship information (e.g., information necessarily processed in connection with a project or contractual relationship, such as orders placed, payments made, requests, and project milestones, or other information voluntarily provided)
- Internet and device information (e.g., device and user identifiers such as IP address and cookie IDs; operating system and version; approximate geographic region; pages/services accessed; date/time of requests; and metadata and user behavioral metrics about use and interaction with our Online Offerings and marketing emails)
- Compliance and legal documentation (e.g., information required for compliance screening, export control, or customs checks, such as date of birth, nationality, place of residence, ID numbers/identity documents, and information regarding relevant and significant litigation or other legal proceedings where legally required)
- Protected classification information (e.g., residency and work permit status, race, gender, and ethnicity in connection with your employment or potential employment with us)
- Employment information (e.g., work history, technical skills, educational background, professional certifications, licensing and registrations, language capabilities, training courses attended, salary history and expectations, performance appraisals, and letters of recommendation)
- Government identifiers (e.g., Social Security Number, driver’s license number, passport number)
- Applicant information (e.g., information on your resume or contained in an employment application, including references, employment history, training, or educational history)
1.2. Purposes:
- Provide and operate our Online Offerings and otherwise provide our services, including creating and administering accounts, providing functionality, support, updates, troubleshooting, security, and improving and developing our offerings
- Process transactions and manage the business relationship, including processing orders, providing access to requested information or offers, arranging shipments and deliveries, facilitating repairs, and delivering related services
- Billing and payments, including invoicing, payment processing, accounting, auditing, billing and collection activities, and (where applicable) billing for your use of the Online Offering
- Verify identity where necessary (e.g., to administer accounts, complete transactions, or meet legal and compliance requirements)
- Communicate with you and respond to requests, including responding to inquiries, fulfilling requests or instructions, and providing information about purchased products and services
- Marketing and engagement, including contacting you with information and offers about our products and services, conducting customer satisfaction surveys as described in Section 2, and (where applicable) creating a business-related profile about interactions with you to provide relevant information and improve communications
- Administer business activities and events, including market analysis and customer activities or events (e.g., sweepstakes, contests, or similar activities where applicable)
- Recruitment and employment-related purposes, including evaluating job applications, verifying applicant information and qualifications, conducting interviews, communicating with applicants, performing background/reference checks where permitted by law, onboarding successful candidates, administering employment relationships, and managing workforce-related processes
- Security and fraud prevention, including maintaining and protecting the security of our products, services, websites, and IT systems, and preventing, detecting, and investigating security threats, fraud, and other criminal, malicious, or illegal activities (including attacks on our IT systems)
- Compliance and screening, including complying with legal obligations (such as recordkeeping), export control and customs requirements, and compliance screening obligations (including to help prevent white-collar crime or money laundering), and complying with applicable policies or industry standards
- Legal enforcement and dispute resolution, including enforcing contractual terms (including Online Offering terms), resolving disputes, and establishing, exercising, preserving, or defending legal claims
2. Processing of personal data for customer satisfaction surveys and for direct marketing
Where and as permitted under applicable law, we may process your contact information for direct marketing purposes (e.g., trade show invitations, newsletters with further information and offers concerning our products and services) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these purposes at any time by writing to Privacy@toyota-al.com or by using the opt-out mechanism provided in the respective communication you received.
3. Information we collect automatically
As you use our Online Offering, we may use technologies that collect certain information about you automatically depending on where you are located. To do this, we may use different technologies that give us information about how you access and use our Online Offering. For more information, please see our “Cookies and Other Technologies” section below or Cookies page.
4. Personal data we collect from other sources
We may also collect personal data that is provided to us about you from our third-party service providers, affiliates, customers, and business partners, including our marketing and advertising partners and social media networks. We may also collect personal data about you from publicly available sources.
5. Cookies and other tracking technologies
As is standard practice on many corporate websites, our Online Offering use “cookies” and other technologies depending on where you are located. Information collected through cookies and other technologies include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Where permitted, we use this information to analyze trends and traffic patterns, to administer the Online Offering, to track users’ movements around the Online Offering and to gather demographic information about our user base as a whole. We may also use cookies and other technologies to (i) help us understand which parts of our Online Offering are the most popular, where our visitors are going, and how much time they spend there; (ii) to make sure that our online advertising is bringing users to our products and services; and (iii) to customize your experience and provide greater convenience each time you interact with us.
5.1. Cookies
We think it is important that you understand cookies. A cookie is a small text file that is sent to your browser when you access a website, including the services. We and the third parties described below may use session cookies. A session cookie is available only during the course of the browser session; the information is not sent to or stored on a computer’s hard drive. Closing the browser or logging off will invalidate the session cookie. You also have the choice to enable a persistent cookie, which will remember your login information each time you visit the Online Offering.
5.2. Web Beacons.
“Web beacons” or “tracking pixels” are electronic images, tags or scripts that allow a website to access cookies and among other things, help track general usage patterns of visitors to a website. Web beacons can recognize certain types of information, such as cookies, time and date of a page view and a description of the page where the web beacon is placed. We and the third parties described below may use web beacons to compile information regarding your use of the Online Offering depending on where you are located.
5.3. Your Options.
Depending on where you are located, when accessing our Online Offering, you may have the option to opt-in to certain optional cookies. However, necessary or essential cookies may be served without opt-in. Further, you can also disable the use of cookies by our Online Offering. However, please note that certain features of the Online Offering will not be available or may not function properly once cookies are disabled. Information on deleting or controlling cookies can be found at www.aboutcookies.org.
6. Transfer and disclosure of personal data
We will transfer or disclose your personal data to any other person as specified at the point of collection and as otherwise set out in this Privacy Notice. We may also disclose your personal data as you direct us to or where you have consented to such disclosure. We may disclose, and have disclosed in the past 12 months, personal data to the following third parties:
6.1. Affiliated Companies and sales partners
For the purpose of and to the extent necessary to conduct our business relationship with you, we may disclose your personal data with affiliates and other third parties (e.g., sales partners and agents). We, for example, sell certain products and services only via local business relationships and in this case, we may disclose your personal data to our respective local affiliates or other sales partners conducting the business relationship with you.
6.2. Transactions
Via our Online Offerings we make available products, services and offerings of affiliates and other third parties. We disclose personal data related to those transactions with that affiliate and/or third party.
6.3. Service Providers
We employ affiliates and other companies to perform functions on our behalf, such as IT- services marketing/analytics/advertising services, or payment processing services.
6.4. Other third parties
We may disclose personal data with a buyer, successor in interest, or any other party involved in a merger, acquisition or other sale or transfer of all or some of our assets, equity or business or any similar transaction, or as part of a bankruptcy, liquidation, dissolution or similar proceeding, as well as advisors, lawyers, accountants and other third parties that may assist in the negotiation, review, and consummation of any such transaction or proceeding. We may also disclose personal data to other third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to regulators, law enforcement and government authorities, to attorneys and consultants). Further, in the employment context, we may disclose personal data with our customers.
The recipients of your personal data may be located outside of the country in which you reside. Personal data published by you on Online Offerings (such as chat rooms or forums) may be globally accessible to other registered users of the respective Online Offering.
7. Retention Periods
Unless indicated otherwise at the time of the collection of your personal data (e.g. within a form completed by you), we erase your personal data if the retention of that personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or to comply with legal obligations (such as retention obligations under tax or commercial laws).
8. Your rights
The data protection laws in the jurisdiction in which you reside may entitle you to specific rights in relation to your personal data. For further information regarding country-specific rights in the US and China, please see Sections 13 and 14 below.
In particular, and subject to the legal requirements, you may be entitled to
- Right to Know: The right to request any or all of the following information relating to your personal data we have collected and disclosed, upon our verification of your identity:
- The categories of personal data we have collected about you.
- Our business purpose for collecting that personal data.
- The categories of third parties with whom we disclose that personal data.
- The specific pieces of personal data we have collected about you.
- The categories of sources of the personal data we have about you.
- Right to Request Deletion: The right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions.
- Right of Portability: The right to request a copy of your information in an accessible format.
- The Right to Correct: The right to correct inaccurate personal data that we maintain about you.
- The Right to Withdraw Consent or Limit Processing: Where processing of personal data is based on consent, you have the right to withdraw your consent at any time. Where processing of personal data is based on legitimate interest, you also have the right to request we limit or restrict how we use your information.
- The Right to Opt-Out of the Targeted Advertising, the Sale or Sharing of Your Personal Data, and Profiling in Certain Circumstances: The right to direct us not to sell or share personal data we have collected about you to third parties for targeted advertising.
- The Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising these rights.
- “Shine the Light”: California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data to a third party for the third party’s direct marketing purposes.
- The Right to Appeal: The right to appeal our decision regarding your request within a reasonable time period dependent on applicable law.
- The Right to Make a Complaint: The right to make a complaint to your local government or supervisory authority if you feel your rights have been violated.
8.1. Exercising Your Rights
To exercise your rights described above, please submit a verifiable consumer request to us by:
- Emailing us at Privacy@toyota-al.com
Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom it collected personal data or an authorized representative thereof; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may not be able to fulfill your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. To verify your identity, we may request up to three pieces of personal data about you, and we reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.
8.2. Response Timing and Format
We endeavor to respond to a verifiable consumer request within thirty or forty-five days of our receipt depending on where you live. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver the written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
9. Security
To protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we strive to use adequate physical, technical and organizational security measures.
10. Data Privacy Contact
Our Data Privacy Organization provides support with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights. The Data Privacy Organization may be contacted at: Privacy@toyota-al.com.
The Data Privacy Organization will use reasonable efforts to address and settle any requests or complaints you bring to its attention. Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.
11. Data Controller and Data Protection Officer
The specific company identified in the Online Offering as being the operator of the Online Offering is the data controller in the meaning of the General Data Protection Regulation for the processing activities described in this Privacy Notice.
The following Toyota Automated Logistics companies have appointed a Data Protection Officer under Art. 37 GDPR which can be contacted as follows:
| TAL entity | Contact details |
|---|---|
| Toyota Automated Logistics EMEA B.V. | om@v-formation.gmbh |
| Vanderlande Industries B.V. | data.privacy@vanderlande.com |
| Toyota Automated Logistics Americas, LLC | sgrass@toyota-logistics.com |
| Vanderlande Industries Inc. | data.privacy@vanderlande.com |
12. Legal Basis of the Processing
Certain jurisdictions require us to provide you with information on the legal basis of the processing of your personal data.
The legal basis for our processing data about you is that such processing is necessary for the purposes of:
- exercising our rights and performing our obligations under any contract we make with you ("Contract Performance").
- Compliance with our legal obligations ("Compliance with Legal Obligations"); and/or
- Legitimate interests pursued by us ("Legitimate Interest"). Generally, the legitimate interest pursued by us in relation to our use of your personal data is the efficient performance or management of (i) your use of the Online Offerings, and/or (ii) our business relationship with you. Where the below table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interest is not overridden by your interests and rights or freedoms, given (i) the regular reviews and related documentation of the processing activities described herein, (ii) the protection of your personal data by our data privacy processes, (iii) the transparency we provide on the processing activity, and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact our Data Privacy Organization at: Privacy@toyota-al.com;
- In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for us processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation) ("Consent").
| Purpose | Legal Basis |
|---|---|
| Provide and operate our Online Offerings and otherwise provide our services |
|
| Process transactions and manage the business relationship |
|
| Billing |
|
| Verifying identity |
|
| Communicate with you |
|
| Marketing and engagement |
|
| Administer business activities and events |
|
| Recruitment and employment-related purposes |
|
| Security and fraud prevention |
|
| Compliance and screening |
|
| Legal enforcement and dispute resolution |
|
12.1. International data transfers
In the event that we transfer your personal data outside the European Economic Area or United Kingdom, we ensure that your data is protected in a manner which is consistent with the General Data Protection Regulation and/or the UK GDPR, Regulation (EU) 2016/679. Therefore, and if required by applicable law, we take the following measures:
- We disclose your personal data with affiliated companies outside the European Economic Area and/or UK subject to appropriate safeguards for your personal data using an approved and valid personal data transfer mechanism, such as (i) the European Union’s Standard Contractual Clauses or the United Kingdom’s International Data Transfer Agreement; and/or (ii) Binding Corporate Rules.
12.2. Your competent data protection authority
In case of data privacy related concerns and requests, we encourage you to contact our Data Privacy Organization at privacy@toyota-al.com. Besides contacting the Data Privacy Organization, you always have the right to approach the competent data protection authority with your request or complaint.
A list and contact details of local data protection authorities is available here.
13. Further information for US residents
If you are a U.S. resident, then please take note of the following:
13.1. Sale and Sharing of Personal Data
We take your privacy very seriously; so, we want to be transparent about our practices. When you interact with us, we may use, or authorize third-party partners and service providers to use, cookies, web beacons and similar technologies to improve your experience with us depending on your location. Our sharing of your personal data in this way may constitute “selling”, “sharing”, or “targeted advertising” under certain US privacy laws. For example, the term “sale” is broadly defined by the California Consumer Privacy Act and includes sharing personal data for monetary or other valuable consideration.
To the extent that are activities noted above are considered “selling”, “sharing”, or “targeted advertising” under applicable US privacy laws, in the preceding 12 months, we have sold or shared the following categories of personal data for the purpose of showing you ads about our services and products:
- Contact Information
- Internet Information
You have the right to opt-out of this selling, sharing, or targeted advertising and to opt-out of disclosure of your personal data to third parties for the third party’s direct marketing purposes. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by clicking on the “Do Not Sell or Share My Personal Information” link on our website. You do not need to create an account with us to exercise your opt-out rights. For purposes of California law, an opt-out of the sale or sharing of personal data also applies to our disclosures of personal data to third parties for their direct marketing purposes.
In addition, some browsers offer you the ability to opt out of the sharing of your personal data by turning on a Global Privacy Control. You can turn on a Global Privacy Control in your web browser or browser extension or by visiting https://globalprivacycontrol.org/. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. At this time, we endeavor to respond to browser-based opt-out signals sent through the Global Privacy Control.
13.2. Usage by Children
This Online Offering is not directed to children under the age of thirteen. We will not knowingly collect, use, process, or otherwise disclose or sell personal data from children under the age of sixteen without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.
14. Processing under People's Republic of China Personal Information Protection Law
This section applies and provides you with further information if the processing by one of our companies is located within the borders of People's Republic of China ("PRC") or concerns the data of individuals within the borders of PRC.
14.1. Processing of sensitive personal information
According to the PIPL, sensitive personal information means personal information that, once leaked or illegally used, may easily cause harm to the dignity of natural persons grave harm to personal or property security, including information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, etc. as well as the personal information of minors under the age of 14.
In addition to the payment data mentioned in section 2 of this Data Private Statement, we will, in principle, not process your sensitive personal information. In case your sensitive personal information is processed, we will notify you about the necessity of processing and effects on the individual's rights and interests and obtain your specific consent if applicable.
14.2. Transfer and disclosure of personal data
Following the requirements defined in Article 23 of PIPL, additionally to the contents mentioned in section 4, we, in principle, will not transfer or share your personal information to third party controllers, unless (1) obtain your specific consent if applicable, or (2) to fulfill the statutory duties under local laws and regulations.
In the event of any reorganization (including the establishment of new, locally incorporated entities in China and the transfer of existing businesses in China to such new locally incorporated entities), merger, sale, liquidation, joint venture, assignment, transfer or other disposition of all or part of our business (including in connection with any bankruptcy or similar proceedings) involving the transfer of personal data, we will ask the new company or organization holding your personal data to continue to process your personal data in accordance with this Privacy Statement. If the new company or organization holding your personal data needs to use your personal data for purposes not stated in this Privacy Statement, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.
14.3. International Transfer
You acknowledge that your data will be transferred and proceed outside of PRC. We will follow the applicable laws and decisions imposed by the competent authority, and ensure that your data is protected in a manner which is consistent with the PRC Personal Information Protection Law. If you or the company you work for is a Business Partner, please be aware that Toyota Automated Logistics is a multi-national company, and for the purpose of concluding or fulfilling the contract/agreement with you or the company you work for, you understand and agree that we may transfer your personal information to foreign affiliated companies.
14.4. Legal Basis of the processing
The PIPL requires us to provide you with information on the legal basis of the processing of your personal data.
The legal basis for our processing is:
- PIPL Article 13(2) ("Contract Performance");
- PIPL Article 13(3) ("Statutory duties and responsibilities")
- PIPL Article 13(6) ("Process publicly available data");
- PIPL Article 13(1) ("Consent")
14.5. Usage by Children
This Online Offering is not directed to children under the age of fourteen (14). We will not knowingly collect personal data from children under the age of fourteen (14) without prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.