Data Privacy Information for interested parties of CLAAS
Information in accordance with Articles 13, 14 and 26 (2) 2 of the General Data Protection Regulation (GDPR). 

 
Version: 2nd May 2022

In the following Privacy Policy, CLAAS of America, Inc., 8401 South 132nd Street, Omaha, NE 68138, USA (“CLAAS”) has provided information about how the personal data of customers, potential customers and interested parties is processed. If CLAAS processes your data, it is also referred to as “we” or “us”. CLAAS provides information as separate controller, unless otherwise specified in the Privacy Policy. The current version of this Privacy Policy may be downloaded from
https://privacy.claas.com/dpi/coa/customer/1000. You can also receive these at any time free of charge by mail from CLAAS. For this purpose, an informal message is sufficient to the contact data in accordance with No. A.I.
 
Content overview:
A.    General data protection information
B.    Customer support
C.    marketing communication (including customer satisfaction surveys, market and opinion research)
D.    Sale of products and services
E.    Measures for business control and optimisation of our business processes
F.    Cooperation in sales and customer care (including administrative processes)
G.   Event management
H.   Corporate transactions
 

A.    General data protection information

I.    Name and contact details of the controllers and contact details for data protection

The controller is:
CLAAS of America, Inc.
8401 South 132nd Street
Omaha, NE 68138, USA
Contactus@claas.com

The Group Data Protection Officer of the CLAAS Group can be contacted as follows: 
Group Data Protection Officer
FAO CLAAS KGaA mbH
Mühlenwinkel 1 
33428 Harsewinkel, Germany
group.dpo@claas.com

II.    Storage period

We only store your personal data for as long as necessary to achieve the purpose for which it was collect-ed or processed. If necessary, we will save your data for the duration of the business relationship. This in particular includes the initiation and execution of the contract.
We also store your personal data if and for as long as necessary to fulfil contractual or legal obligations. We therefore process your data to fulfil commercial or tax law proof and retention obligations.
If the data is no longer required for the fulfilment of contractual or legal obligations, it is usually deleted unless you have given us your consent to process your data and/or further processing is necessary on the basis of our legitimate interests, e.g. to win back customers or defend against legal claims in litigation. When processing data to defend against legal claims in litigation, the storage period is also based on the statutory limitation periods (e.g. civil law and product liability law). In this case, processing will be restricted, i.e. restricted to the minimum necessary for this purpose and blocked for other purposes.
The above does not apply if specified otherwise in the special Privacy Policy.

III.    Categories of recipients

1. Carefully selected service providers. Service providers we have commissioned and who support us in executing the business relationship will receive access to the data. These are companies in the cat-egories of hosting providers, data management, software as a service, email services, IT services (e.g. maintenance and support, data migration), consulting, service providers within the context of first, second and third-level support, call centre services, customer management, lettershops, market-ing, media technology, telecommunications, customer relationship and lead management, tracking service providers, web agencies, compliance, disposal services (e.g. document shredders), compa-nies which carry out analyses for us, financial management service providers, shipping and logistics services, printing services, technology service providers (e.g. for hardware and accessories). Please refer to the respective special Privacy Policy for any further categories of service providers used. 
 
2. Data transfers within the CLAAS Group.

a.  by CLAAS to CLAAS KGaA mbH (Mühlenwinkel 1, 33428 Harsewinkel, Germany) for internal administrative purposes, in particular master data management, ensuring compliance requirements (e.g. preventing the infringement of money laundering bans) and proper business processes, per-forming audits and special reviews, internal investigations and group reporting, group accounting, controlling, risk management, reporting, safeguarding operations and the restoration of IT systems (logging, monitoring, defence against unauthorised access, incident management, processing of data protection rights and the fulfilment of our and their sales, service and administrative purposes, assertion of legal claims, defence in litigation

b.  by CLAAS to CLAAS Service and Parts GmbH (Mühlenwinkel 1, 33428 Harsewinkel, Germany) for the purpose of promotional communication, reporting and the provision of products and ser-vices which have been requested or used, including procurement (e.g. direct delivery of spare parts for harvesting), use of support services (e.g. product and customer support), review of war-ranty, goodwill and reimbursement claims, price calculation quality assurance, improvement of business processes, assertion of legal claims, defence in litigation

c.  by CLAAS to CLAAS Global Sales GmbH (Mühlenwinkel 1, 33428 Harsewinkel, Germany) for the purpose of the further development and improvement of products, services and processes, re-porting, provision of requested or used products and services, use of support services (e.g. prod-uct and customer support), marketing communication, assertion of legal claims, defence in litigation

d.  Data transfers from CLAAS group companies to CLAAS 
  • by CLAAS Global Sales GmbH to CLAAS for the purpose of providing requested or used products and services, making use of support services (e.g. product and customer support), tracking and responding to your enquiries (e.g. if you submit an enquiry through them offline or using online applications operated by them if CLAAS or a CLAAS authorised dealer in the CLAAS sales territory is responsible for processing these enquiries), marketing communica-tion, new customer acquisition, sales management, the improvement of our products, services and business processes
  • by CLAAS Service and Parts GmbH to CLAAS for the purpose of providing technical sup-port and requested or used products and services, including procurement, tracking and re-sponding to your enquiries (if you submit an enquiry through them offline or using online appli-cations operated by them if CLAAS or a CLAAS authorised dealer in the CLAAS sales territory is responsible for processing these enquiries), quality assurance, improvement of our busi-ness processes, provision of support services (e.g. product and customer support), review of reimbursement claims (e.g. warranty, goodwill and reimbursement claims), price calculation, promotional communication, assertion of legal claims, defence in litigation
  • by CLAAS KGaA mbH to CLAAS for tracking and responding to your enquiries (e.g. if you submit an enquiry through them offline or using online applications operated by them if CLAAS or a CLAAS authorised dealer in the CLAAS sales territory is responsible for processing these enquiries), for internal administrative purposes, in particular master data management, for the purpose of ensuring compliance requirements and proper business processes, business con-trol, risk management, securing the operation and restoration of IT systems (logging, monitor-ing, defence against unauthorised access, incident management, processing data protection rights, fulfilment of our and their sales, service and administrative purposes, assertion of legal claims, defence in litigation
e. We pass on data updates to companies in the CLAAS Group from your address database for the purpose of processing accurate data. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Our legitimate interest lies in the afore-mentioned purpose. For further information, please contact CLAAS at any time (see Section AI).

f. The legal basis for the data transmission according to Section III.2. is Art. 6 (1) 1 point f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Que-bec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 on the basis of our legitimate interests in the fulfilment of the purposes mentioned therein. If your data is passed on in order to initiate a contract on your initiative or if transmission of this data is necessary to fulfil con-tractual obligations or takes place with your consent, the legal basis is Art. 6 (1) 1 point b GDPR or Art. 6 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Where we are obliged to transfer the data by law, the legal basis is Art. 6(1) 1 c GDPR; Sec-tion 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. For other forwarding of data to third parties, please refer to the particular information on data protection.
 
3. Data transmission to third parties with whom CLAAS has an ongoing business relationship (in particular CLAAS authorised dealers) in order to track and respond to your enquiries (e.g. if you submit an enquiry offline or online to CLAAS or CLAAS group companies which CLAAS or a CLAAS authorised dealer in the CLAAS sales territory is responsible for processing, e.g. a request for a test drive, requests for quotations), for the purpose of acquiring new customers and customer care (in-cluding jointly with the CLAAS authorised dealer), sales management, including success monitoring. If you have not selected a CLAAS authorised dealer, we will forward your request to the CLAAS author-ised dealer responsible for you in your region. We pass on data updates to CLAAS authorised dealers which you have added to your address database. Furthermore, CLAAS also transmits your data to your CLAAS authorised dealer for the purpose of fulfilling contractual obligations within the context of performing or arranging test drives and machine demonstrations, training courses, for price calcula-tions, processing orders, checking warranty, guarantee and goodwill applications, brokering financing, for event registration, for the purpose of quality assurance, product monitoring, product defence and product safety, product improvements, improvement of our sales and service processes, carrying out market analyses, processing data protection rights, direct marketing, customer data management, re-ferring interested parties. The legal basis for the data transfers according to Section III.3. is Art. 6 (1) 1 point f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 on the basis of our legitimate interests in the fulfilment of the aforementioned purposes. If your data is passed on in order to initiate a contract or if transmission of this data is necessary to fulfil contractual obligations or takes place with your consent, the legal basis is Art. 6 (1) 1 point b GDPR or Art. 6 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Where we are obliged to transfer the data by law, the legal basis is Art. 6(1) 1 c GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. 
 
4. Forwarding to selected third parties. We also pass on your data to third parties if permitted or re-quired by legal or contractual provisions and/or if you have given your consent. Subject to this, the da-ta may be transferred to the following categories of recipients: Public bodies and institutions (e.g. pub-lic prosecutor's office, police, tax authority, supervisory authority) for processing official inquiries, to the extent that this is in your interest or we are legally obliged to do so. The legal basis for this is Art. 6 (1) 1 points f and c GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Within the context of corporate transactions, we also pass on your data to companies which transfer our rights to within the scope of a potential sale in one or more business areas. We also pass on your data to banks and financial institutions in order to process payments or fulfil the brokerage contract with the financial service provider you have selected, to auditors, lawyers and tax consultants within the context of audits, to ensure compliance and support in compliance with legal requirements and for the assertion of claims and defence in litigation. The legal basis is our legitimate interest in the fulfil-ment of a brokerage contract for financing, the assertion of claims and defence in litigation, the fulfil-ment and review of our processes and applicable legal regulations, Art. 6 (1) 1 point f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574.

IV.    Source of the data

1. Information we collect from you. We process the personal data (hereinafter referred to as the “data”) we receive from you when
a.    Transactions are initiated and contracts are processed 
b.    You purchase or use our products, services or other offers or get in 
       contact with us
c.    You consent to promotional messages
 
2. Information we receive from third parties. We also process data we are permitted to use which we receive from 
a.    the companies listed in Section A.III.2. and 3. of the CLAAS Group
       for the purposes named therein
b.    Credit agencies and creditor protection associations for the purpose
       of credit checks,
c.    Public authorities for the purpose of answering government
       inquiries, as well as 
d.    Other third parties with whom we have a (long-term) business
       relationship: such as your CLAAS authorised dealer as well as other
       third parties, such as certified address sellers
 
3. Data from publicly available sources. We also process data which we legitimately obtain from pub-licly accessible sources (e.g. commercial register, company register, land register, debtor registers, insolvency notices, media, sanction lists) for the purpose of fulfilling compliance and legal require-ments, risk management, verification of data (e.g. address validation), acquisition of new customers, conducting market research.

V.    Forwarding to third countries

Data will be transferred to third countries (countries outside the EU or the European Economic Area – EEA) if, for example, this is
  • necessary to fulfil a contract to which you are a party or in response to your enquiries,
  • necessary to safeguard our legitimate interests,
  • prescribed by law, or if you have given us your consent,
carried out during processing where service providers are involved.
If we transmit your personal data ourselves or through service providers in countries outside of the EU or the EEA, we comply with the special requirements of Art. 44–49 GDPR and also oblige our service provid-ers to adhere to these regulations. We therefore only transfer your data to countries outside the European Union which are subject to the level of protection guaranteed by the GDPR. This level of protection is in particular ensured on the basis of an adequacy decision by the EU Commission, Art. 45 GDPR, through binding internal data protection provisions according to Art. 47 GDPR or by corresponding contracts, in particular by agreeing on the EU Standard Contractual Clauses of the European Union with the recipient. Otherwise, we can also transmit data on the basis of your express consent. The legal basis for this is Art. 49 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. You can revoke your consent at any time with future effect, see Section A.VII. We can provide you with more detailed information free of charge upon request using the contact details above. 
Kindly take note that the following risks exist insofar as we use your consent as the sole basis for pro-cessing by recipients that do not provide an adequate level of data privacy: There may not be sufficient rules for the adequate protection of your personal data; there is no supervisory authority for data privacy; the exercise of your data privacy rights may be difficult or disregarded; there are no controls over the pro-cessing and transfer of data to third parties.
We would be glad to provide you with more detailed information at no charge. Simply send a request to us using the contact information provided above. 

VI.    Obligation to provide personal data 

Unless otherwise specified in the particular information on data privacy, you are under no legal or contrac-tual obligation to provide your data.

VII.   Rights of the data subject
 
In accordance with Art. 15 GDPR, you have the right to obtain information about your stored data. If incorrect personal data has been processed, you have the right to rectification in accordance with Art. 16 GDPR. If the legal requirements are met, you can demand erasure of your personal data or restriction of their processing and object to the processing of your data (Articles 17, 18 and 21 GDPR). According to Art. 20 GDPR, you can exercise your right to data portability with regard to the data which are processed by automated means based on your consent or on a contract with you.
 
Information regarding your right to object according to Art. 21 GDPR

 
  1. You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6 (1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 (data processing based on a balancing of interests). This also applies to profiling as defined in Art. 4 (4) GDPR which is carried out on the basis of this provision and which is used by CLAAS for solvency checks or marketing purposes.

If you object, CLAAS will no longer process your personal data unless CLAAS can prove compelling reasons for processing which are worthy of protection and which outweigh your interests, rights and freedoms, or unless the processing serves the establishment, exercise or defence of legal claims.

 
  1. CLAAS processes your personal data in order to conduct direct marketing. You have the right to object at any time to the processing of data concerning you for the purpose of such marketing, including profiling, to the extent it relates to such direct marketing.

If you object to processing for direct marketing purposes, CLAAS will no longer process your personal data for these purposes.

You may object without adherence to any formal requirements by addressing your notification, if possible, to privacy.coa@claas.com

 
 
Right to withdraw your consent in accordance with Art. 7 (3) GDPR

Where you consented to the processing of your personal data, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the legality of the processing carried out on the basis of your consent up to the point of withdrawal.

Withdrawal of consent does not require any specific form and may be sent to the contact addresses provided in Part A. II. Should CLAAS provide additional options for withdrawing consent (e.g. unsubscribe link in every newsletter email), you will be advised of this in the particular information on data privacy.

 

B.    Customer Support

We process your data for the purpose of customer service. We do this based on our legitimate interest in optimal advice on products and services and the efficient tracking of enquiries and complaints
  • Responding to your enquiries (e.g. enquiries about a test drive, service or specific offer, callback requests, enquiries to our customer services, complaints, brochures, ordering spare parts, etc.). If you submit an enquiry via CLAAS, online or using the contact details of CLAAS or the CLAAS group companies (e.g. connect.claas.com or claas.com, customer hotline) or a CLAAS authorised dealer, we will process your data so that your enquiry is directed to the right contact person within our sales and service organisation (e.g. the responsible CLAAS employee or the authorised dealer you have selected or, if you have not made a selection, the CLAAS authorised dealer responsible for you in your region) and ensure that your enquiries are followed up in good time. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Our legitimate interest lies in the efficient tracking and answering of your enquiries within the scope of our customer service. If your request is aimed at the conclusion, execution or processing of a contract, Art. 6 (1) 1 point b GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 are the le-gal basis. For this purpose, we typically process personal identification data, contact data, operating data, customer type, information and analyses relating to interests and user behaviour, planning and control data, contract and order data, electronic identification data, authentication data, communica-tion data, technical documentation and log data, technical documentation and log data, inventory da-ta, movement data, photos, machine data (machine master data, machine operating data, machine performance data), service and maintenance data.
  • Customer care, with the involvement of the CLAAS authorised dealers selected by you or regionally responsible for you (e.g. advice on products and services tailored to your needs and interests). In order to offer you the best possible customer experience, CLAAS and CLAAS authorised dealers work together closely to provide sales and customer service. This includes the documentation and planning of activities and tasks within the context of customer care, sales management and new customer acquisition, machine demonstrations, test drives, training courses and other events, in-cluding the provision and logistics for everything relating to the machine and the availability planning of CLAAS and CLAAS authorised dealer employees with the expertise to respond to your enquiries, as well as the preparation of reports and analyses. This also serves to procure interested parties and control and optimise business processes. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Our legitimate interest lies in the provision of optimal customer service, sales management, the control and optimisation of business processes and the assertion of claims or defence in litigation. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. The legitimate interest of CLAAS and CLAAS authorised dealers lies in the purposes mentioned above. If your data is processed in order to initiate a contract on your initiative or to fulfil contractual obligations or if this takes place with your consent, the legal basis is Art. 6 (1) 1 point b GDPR or Art. 6 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Where we are obliged to transfer the data by law, the legal basis is Art. 6(1) 1 c GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. We typically process the following data for the purpose of customer care, including processing and tracking your enquiries: Personal identification and contact data, operating data, type of customer, information and analyses about interests and user behaviour, planning and control data, contract and order data, commu-nication content data, technical and professional documentation and log data, service and maintenance data.
For the above-mentioned purposes, we also process data which we receive from your CLAAS authorised dealer or CLAAS, companies of the CLAAS Group (see Section IV.2.a.) and public sources (see Section IV.3.) and pass on your data to the recipients named in Section A.III. for the purposes mentioned therein.

C.    Marketing communication (including customer satisfaction surveys, market and opinion research)

I.    Marketing communication

CLAAS, CLAAS KGaA mbH, CLAAS Global Sales GmbH, CLAAS Service and Parts GmbH (hereinafter jointly referred to as “the parties” in this Section, see also No. II. of this section) use your data for the purpose of marketing communication.
Marketing communication includes the CLAAS brand as well as products from third-party suppliers sold by the companies of the CLAAS Group, insofar as these are products which complement the products of the CLAAS brand or support them in their function (e.g. tillage equipment, fertilisation, application equipment, precision sowing technology, spraying, farm management software). Contact is made via the channels specified in the declaration of consent (e.g. post, email including newsletters, telephone/messenger ser-vices, push notifications, e.g. on websites, apps). If you consent to the transmission of promotional push messages for websites or apps, we will send you push messages from the following apps: claas.com, con-nect.claas.com, CLAAS connect App.
The legal basis for this data processing is your consent, Art. 6 (1) 1 lit. a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. You can revoke your consent at any time with future effect, see Section A.VII.
For this purpose, the Parties jointly process the following data:
  • Personal identification data (e.g. surname, first name, address, CLAAS ID, title and operative func-tion, date of birth)
  • Contact details (phone number, email address)
  • Company data (name of the company, address, activities, company size, fleet information, cus-tomer number, operating history (e.g. date of purchase or first use of your machine), sales data, information about activities carried out (e.g. customer visits, product demonstrations), 
  • Information and analyses about interests and user behaviour (e.g. interest in products, customer interest, preferred or selected communication channels, investment or purchase interest, infor-mation on purchased or rented products and services used (e.g. test drives, machine demonstra-tions, events, platforms such as CLAAS Connect, applications, financing), customer history, sales data, information about opens, clicks and bounces from newsletters, apps, websites and social media channels, information which is legitimately obtained about people, for example using cus-tomer needs and potential analyses, such as possible times when you may need a new machine, spare part or service, marketing history and response to direct marketing measures, feedback from customer satisfaction surveys)
  • Machine data (machine master data, machine performance data and machine operating data, i.e. such as the machine number and associated attributes such as the manufacturer, product catego-ry, product group, product classification, model, machine type, equipment, configuration, hectares worked, number of bales produced, loads performed, operating hours)
This is data which the parties jointly collect with your marketing consent for the purpose of direct market-ing, data which you provide to one of the parties within the context of the business relationship and data which results from the use of products, services or benefits of the above-mentioned parties. The parties combine this data to create a user profile about you and assign it to your profile in our database (CRM, please see section F). The parties use the data and information obtained in this way to determine which information and offers are most likely of interest to you and to contact you for marketing purposes. The aim is to tailor our marketing to your interests and optimise our offers for you. 
In individual cases and only after careful consideration, the parties will contact you for marketing purposes relating to the CLAAS brand (e.g. offer of additional services, promotional introduction to products and services, invitation to events such as product presentations, market and opinion research, customer satis-faction surveys) as well as products from third-party providers sold by the companies of the CLAAS Group or the CLAAS authorised dealer, insofar as these are products which complement the products of the CLAAS brand or support them in their function (e.g. tillage equipment, fertilisation, application equipment, precision sowing technology, spraying, farm management software), including without marketing consent. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. A prerequisite for direct marketing based on legitimate interests is that the applicable legal requirements are met, that you are aware of the processing of your data for the purpose of marketing and that you are aware of your right to object in accordance with Art. 21 GDPR (see also Section A.VII. of this data protec-tion information) and have not objected.
The legal basis for the storage of technical and professional documentation and log data for the purpose of documenting your consent is Article 6 (1) 1 points c and f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. The marketing communication is usually distributed by service providers (e.g. marketing agencies, lettershops, IT service providers, CRM, messenger service providers) who act as commissioned data processors. These may also include service providers based in a third country, including the USA, UK; see Section AV (third country transfer).

II.    Joint responsibility

CLAAS, CLAAS KGaA mbH, CLAAS Global Sales GmbH and CLAAS Service and Parts GmbH process the data of customers, interested parties and potential customers when obtaining marketing consent and collection and use of the data for marketing purposes (insofar as the imprint of the marketing measure discloses two or more parties as sender). 

1. Name and contact details of the jointly responsible controllers, including contact details of the Data Protection Officer
The jointly responsible controllers are:
CLAAS of America, Inc.
8401 South 132nd Street
Omaha, NE 68138, USA
contactus@claas.com


 		 CLAAS Global Sales GmbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
infoclaas@claas.com
 
CLAAS KGaA mbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
infoclaas@claas.com
 		 CLAAS Service and Parts GmbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
infoclaas@claas.com
 

Contact details of the Data Protection Officer or the contact person for data protection:
Contact the Data Protection Officer of CLAAS KGaA mbH, CLAAS Global Sales GmbH and CLAAS Service and Parts or for CLAAS the contact person for data protection issues at CLAAS at
Group Data Protection Officer
FAO CLAAS KGaA mbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
group.dpo@claas.com
 
2. For which process sections is there joint responsibility?
The companies of the CLAAS Group and CLAAS authorised dealers listed in Section 1 (collectively referred to as the "Parties") work closely together for the sales and marketing of products and services of the CLAAS Group. They are therefore jointly responsible for protecting your personal data within the procedural steps described below (Art. 26 GDPR):
There is joint responsibility for the following process steps:
  1. Collection and use of the data for marketing purposes (insofar as the imprint of the marketing measure discloses two or more parties as sender)
  2. Obtaining marketing consent
  3. Documentation of the declaration of consent

3. What have the parties agreed?
Within the scope of their joint responsibility under data protection law, the parties have agreed who will fulfil which obligations under the GDPR. This in particular applies to your rights and the fulfilment of duties to provide information in accordance with Articles 13, 14 and 26 GDPR.
Processing steps
 		 Jointly controlled by
 		 Fulfilment of the obligations according to Art. 13, 14, 26 GDPR
 		 Implementation of the rights of the data subjects
 
Collection and use of the data for marketing purposes (insofar as the imprint of the marketing measure discloses two or more parties as sender)
 		 CLAAS of America, Inc., CLAAS KGaA mbH, CLAAS Global Sales GmbH, CLAAS Service and Parts GmbH
 		 The party who collects the data from you
 		 Data subjects can contact each of the joint controllers with regard to the assertion of data subject rights. Irrespective of this, the parties have agreed that CLAAS of America, Inc., 8401 South 132nd Street, Omaha, NE 68138, USA, e.g. by E-Mail to: contactus@claas.com
 will act as a common point of contact in accordance with Art. 26 (1) 3 GDPR. If CLAAS KGaA mbH, as operator of the basic system architecture, is required to fulfil the data subject rights – in particular in relation to requests for erasure and the right to data portability – it shall implement the relevant data subject rights in cooperation with the other joint controllers for their information.
 
Obtaining marketing consent
 		 CLAAS of America, Inc., CLAAS KGaA mbH, CLAAS Global Sales GmbH, CLAAS Service and Parts GmbH
 		 The party who obtained marketing consent

 
Documentation of the declaration of consent
 		 CLAAS of America, Inc., CLAAS KGaA mbH, CLAAS Global Sales GmbH, CLAAS Service and Parts GmbH
 		 The party who obtained marketing consent

 

D. Sale of products and services
 
We process your data for the distribution and sale of our products and services within the context of the initiation, execution and processing of contracts, in procurement and logistics (e.g. when you purchase a licence or a used machine or book driver training) and within the context of contractual maintenance and repair obligations, billing and checking reimbursement claims and providing you with the products and services you have requested. The purposes and scope of the data processing depend on the specific product or service used. The legal basis is Article 6 (1) 1 point b GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574, unless otherwise specified in this Section.
 
      • Planning and implementation (and mediation if necessary) of test drives and machine demonstrations; for this purpose, we typically process personal identification and contact data, operating data, the type of customer, machine data (machine master data, machine performance data and machine operating data), planning and control data, information and analyses about interests and user behaviour of customers and contact persons, service and maintenance data, contract and order data
      • Planning and implementation (if necessary brokerage) of driver training, product and service training, e.g. when introducing a machine you have purchased or implementing other training courses. For this purpose, we typically process personal identification and contact data, operating data, the type of customer, contract and order data, machine data (machine master data, machine performance data and machine operating data), planning and control data, information about the interests of customers and contact persons, service and maintenance data.
      • Preparation of offers, sale of products, provision of services (e.g. software maintenance contracts for EASY products), licences (e.g. EASY licences) including delivery. For this purpose, we typically process personal identification and contact data, operating data, customer type, contract and order data (e.g. contract number, information about the term of contracts, the start and end of warranty, order number, prices, contract and order content, licence used, licence status, communication content data, billing and payment data), financial identification data, machine data (e.g. machine number), planning and control data. If your price expectations cannot be met by CLAAS as a supplier without the provision of sales assistance, CLAAS authorised dealers will provide your data to CLAAS for the purpose of providing sales assistance. The legal basis is Article 6 (1) 1 point b GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 or our legitimate interest in optimising pricing for the customer. If you have given your consent, Article 6 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 also form a legal basis.
      • Vehicle return (e.g. trade-in of used machines, purchase of machines). For this purpose, we typically process personal identification and contact data, operating data, customer type, contract and order data, machine data (machine master data, machine performance data and machine operating data), service and maintenance data and photos of machines (e.g. photos to document the condition).
      • Financing brokerage If you wish to finance a (new or used) machine, we typically process the following data on the basis of our brokerage contract (Art. 6 (1) 1 point b GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574) or if you have given your consent (Art. 6 (1) 1 point a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574): Personal identification and contact data, operating data, type of customer, order and contract data, machine data (machine master data, machine performance data and machine operating data) including status data (e.g. machine type, machine number, production date, operating hours, equipment features). For the purpose of fulfilling a brokerage contract, we pass on your data to your selected financing service provider.
      • Sending information materials (e.g. brochures). When you order information materials, we typically process personal identification and contact data according to the communication channel you have selected, operating data, type of customer, communication content data, information and analyses about interests and user behaviour (e.g. your interest in the brochure for a specific product), planning and control data, technical documentation and log data
      • Incentive and commission management.  We process your data to determine and settle sales or seller premiums and bonus payments as well as credits, and to review the underlying requirements for a claim to payment. The legal basis is Article 6 (1) 1 point f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 based on our legitimate interest in acquiring new customers and managing sales. For this purpose, we typically process the following data: Personal identification data, operating data, order data (e.g. orders from CLAAS dealers at CLAAS, sales assistance provided by CLAAS), machine data (e.g. machine type, machine number), planning and control data. If possible, we use your data without personal reference.
      • Registration for factory tours with the manufacturer. If you would like to take part in a factory tour for the manufacturer of your machine, we will process your data for the purpose of planning and processing your participation in a factory tour; CLAAS takes care of the planning and handling of the factory tour (including catering if necessary), which may be provided by another company in the CLAAS Group (e.g. CLAAS KGaA mbH). For this purpose, we typically process the following data: Personal identification and contact data, operating data, type of customer, communication content data, information and analyses about interests and user behaviour, planning and control data, contract and order data. The transfer of data to the implementing company of the CLAAS Group takes place without personal reference. Should it be necessary in individual cases to pass on personal data to the company in the CLAAS Group in order to complete registration, this will only be done if the data protection requirements have been met.
      • Organisation of sweepstakes, competitions and discount campaigns under the respective contractual conditions. For this purpose, depending on the type of sweepstakes, competition or discount campaigns, we process the data required for implementation and processing, including shipping or provision of the prizes. Typically, this includes master and contact details, operating data, type of customer and possibly information and analyses of interests and user behaviour, planning and control data, technical documentation and log data (e.g. declarations of consent).
Further details on the purpose of data processing can be found in the respective contractual documents and terms of use.
For the above-mentioned purposes, we also process data which we receive from your CLAAS authorised dealer, companies of the CLAAS Group (see Section IV.2.a.) and public sources (see Section A.IV.3.) and pass on your data to the recipients named in Section A.III.1.–5 for the purposes mentioned therein.
E. Measures for business control and optimisation of our business processes 
 
We process your data to create reports and analyses within the scope of our reporting, to identify market and sales potential, for sales management, to control and optimise business processes and to acquire new customers. The legal basis for this is Art. 6 (1) 1 point f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. Our legitimate interest lies in the aforementioned purposes.
For this purpose, we typically process the following data: Personal identification data, contact data, operating data, type of customer, information and analyses about interests and user behaviour, planning and control data, contract and order data (including information about business transactions, billing and payment data), communication content data, technical documentation and log data, technical documentation and log data, electronic identification data, usage and traffic data, inventory data, movement data, machine data (e.g. machine master data, machine operating data), service and maintenance data, photos.
For the above-mentioned purposes, we also process data which we receive from your CLAAS authorised dealer or CLAAS, companies of the CLAAS Group (see Section IV.2.) and from public sources (see Section IV.3.) and we pass on your data to the recipients named therein for the purposes mentioned in Section A. III..
F. Cooperation in sales and customer care (including administrative processes)

I. Joint responsibility (Art. 26 GDPR)
The following companies in the CLAAS Group and CLAAS authorised dealers (collectively referred to as the "Parties") work closely together for the sales and marketing of products and services of the CLAAS Group. They are therefore jointly responsible for protecting your personal data within the procedural steps described below (Art. 26 GDPR):
 
  1. Name and contact details of the jointly responsible controllers, including contact details of the Data Protection Officer
The jointly responsible controllers are:
 
CLAAS of America, Inc.
8401 South 132nd Street
Omaha, NE 68138, USA
contactus@claas.com
 (hereafter “CLAAS”)
 		 CLAAS KGaA mbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
infoclaas@claas.com
(hereafter referred to as “CLAAS KGaA mbH”)
 
The CLAAS authorised dealer responsible for you or selected by you
(https://www.claasofamerica.com/sales-financing/dealer-start) (hereafter referred to as “CLAAS authorised dealer”).
You can also call at any time to find out which CLAAS authorised dealer is responsible for you Tel. +1 (402) 861-1000.
 		 CLAAS Global Sales GmbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
infoclaas@claas.com
(hereafter referred to as “CLAAS Global Sales GmbH”)
 

Contact details of the Data Protection Officer or the contact person for data protection:
 
Contact the Data Protection Officer of CLAAS KGaA mbH, CLAAS Global Sales GmbH and CLAAS Service and Parts and for CLAAS the Group Data Protection Officer of CLAAS at
Group Data Protection Officer
FAO CLAAS KGaA mbH
Mühlenwinkel 1
33428 Harsewinkel, Germany
group.dpo@claas.com
 		 If the CLAAS authorised dealer has appointed a Data Protection Officer, you can find his or her contact details on the CLAAS authorised dealer's website. This can also be requested from CLAAS at any time using the contact details above.

 
 
  1. For which process sections is there joint responsibility?
There is joint responsibility for the following process steps:
  1. Provision and management of data relating to customers, prospective customers and potential customers in the customer database
  2. Creation, administration, tracking and documentation of activities in the customer database
  3. Documentation of events, facts and processes, including generation and documentation
  4. Provision and administration of data for a reporting system in the customer database
  5. Initiation and documentation of business deals in the customer database
  6. Provision and further development of the basic system architecture for the customer database
 
  1. What have the parties agreed?
Within the scope of their joint responsibility under data protection law, the controllers have agreed who will fulfil which obligations under the GDPR. This in particular applies to your rights and the fulfilment of duties to provide information in accordance with Articles 13, 14 and 26 GDPR.
 
Processing steps
 		 Jointly controlled by
 		 Fulfilment of the information obligations according to Art. 13, 14, 26 GDPR
 		 Implementation of the rights of the data subjects
 
Provision and further development of the basic system architecture for the customer database

 		 CLAAS KGaA mbH, CLAAS Global Sales GmbH
 		 The party who enters the data subject into the CLAAS customer database shall make the information required according to Art. 13, 14 and 26 GDPR available to the data subject in a precise, transparent, understandable and easily accessible form in clear and simple language free of charge. Each party shall also provide the other party with all necessary information from their area of activity

 		 The parties shall immediately inform each other about your asserted rights as a data subject (see Section A.VII. of the data protection information).

They shall provide each other with all information required to answer requests for information.

Single point of contact. You can assert your rights as a data subject with and against each of the controllers.
Irrespective of this, the parties have agreed that CLAAS of America, Inc.
8401 South 132nd Street
Omaha, NE 68138, USA or by email to privacy.coa@claas.com shall act as a single point of contact in accordance with Art. 26 (1) 3 GDPR.

If CLAAS KGaA mbH, as operator of the basic system architecture, is required to fulfil the data subject rights – in particular in relation to requests for erasure and the right to data portability – it shall implement the relevant data subject rights in cooperation with the other joint controllers for their information.
 
Provision and management of data relating to customers, prospective customers and potential customers in the customer database

 		 CLAAS, CLAAS authorised dealer, CLAAS KGaA mbH, CLAAS Global Sales GmbH
 
Creation, administration, tracking and documentation of activities in the customer database
 		 CLAAS, CLAAS authorised dealer
 
Documentation of events, facts and processes, including generation and documentation

 		 CLAAS, CLAAS authorised dealer
 
Provision and administration of data for a reporting system in the customer database
 		 CLAAS, CLAAS authorised dealer, CLAAS KGaA mbH, CLAAS Global Sales GmbH
 
Initiation and documentation of business deals in the customer database
 		 CLAAS, CLAAS authorised dealer
 
G. Event management

I. Implementing and managing events (including trade fairs)
 
If you have registered for events or take part in our events, we process the data necessary for the implementation and management of the event. The legal basis is Art. 6(1) 1 lit. b GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. For this purpose, we typically process personal identification and contact data, operating data, customer type, communication content data (e.g. sending confirmation of participation), technical documentation and log data (e.g. log data within the scope of the registration process), information and analyses about interests and user behaviour, contract and order data (e.g. for the event you have booked, billing and payment data), planning and control data.

II. Reporting on events
 
If you participate in our events (including trade fairs), we process data in order to report on the event. Photos and/or videos are regularly taken at our events, some of which are published on our homepage in our external and internal reporting. In addition to the photo and film recordings, metadata such as the time and place of the recording and the location are also automatically saved in the digital cameras. The legal basis for taking and storing photo and video recordings is Art. 6 (1) 1 lit. f) GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 on the basis of our legitimate interest in internal and external reporting on the event for public relations. The legal basis for the publication of the photo and video recordings is Art. 6 (1) 1 lit. f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574 in the case of public events (e.g. at trade fairs) or events in the public sphere or if they only incidentally appear in the photo and the reporting on the event is in the foreground. In addition, we only publish recordings of you with your consent, Art. 6 Para. 1 S. 1 lit. a GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574.

H. Corporate transactions
 
We also process your data in the case of corporate transactions, e.g. if we want to sell specific divisions. In this context, we may disclose data to interested parties as part of the due diligence. In doing so, we anonymise your data as much as possible and otherwise generally only transfer it in a pseudonymised manner. We use a data protection management system for corporate transactions to ensure that we comprehensively protect your data. The processing of your data as part of due diligence (e.g. preparation of due diligence reports, transmission to interested parties) is based on our legitimate economic interest in changing our business operations in line with the market. The legal basis is Art. 6(1) 1 f GDPR; Section 26 (1) 1 BDSG; PIPEDA Sec. 6.1; BC PIPA Part 3, Sec. 6; AB PIPA Div. 2, Sec. 7; Quebec Private Sector Act Div II, Sec. 6; CCPA 1798.100; and VDPCA 59.1-574. For this purpose, we typically process personal identification data, contact data, operating data, contract and order data, service and maintenance data, technical and professional documentation and log data, planning and control data, information and analyses about interests and usage behaviour, machine data.