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Zur UmfrageData protection notice relating to the online account of the Vodafone GmbH company pension plan
We provide information about your company pension!
We, Willis Towers Watson GmbH, as a service provider, process your personal data on behalf of Vodafone GmbH in the context of the online company pension account we provide for Vodafone GmbH and its subsidiaries. With these applications, we inform you about the individual status of your company pension at Vodafone GmbH and provide you with more information relating to company pensions. In addition, we inform you about your rights under applicable data protection law.
Personal data means any information that relates to an identified or identifiable natural person, for example personal details, address data and accounting data, which reflect a person’s identity.
The personal data you have entered in our online account are processed by us, or the respective legal entities of Vodafone GmbH, for the purposes of determining and administering your company pension claims.
Company pension claims are established in connection with your employment with a Vodafone GmbH company and handled by employees of Willis Towers Watson, the responsible business departments, or by HR departments.
We respect your privacy
The protection of your privacy in the processing of personal data as well as the security of all business information are important issues for us, which we take into account in our business processes. We will process personal data collected during your visit to our online offerings on a confidential basis and only in compliance with statutory provisions.
Data protection and information security are part of our corporate policy.
Contact information of the controller for data processing and the data protection officer
The controller for the processing of your data is the respective legal entity of Vodafone GmbH where you are employed. Willis Towers Watson acts as processor in the sense of Article 28 of the EU General Data Protection Regulation (GDPR) on behalf of Vodafone GmbH.
You can reach our Data Protection Officer at the following address:
Data Protection Officer
Willis Towers Watson GmbH
Wettinerstr. 3
65189 Wiesbaden
Deutschland
oder
Please contact the Data Protection Officer to assert your rights and to report data protection incidents.
Your company pension
In connection with your employment with a Vodafone GmbH company, you may have received a company pension promise. Your entitlement to a company pension is explained in detail in this application, the online account.
Processed data categories
The categories of personal data processed include in particular:
- Master data (e.g. name; date of birth; residence)
- Duration of employment with the company or group; status (active/non-active); position; leaving date
- Detailed information about pay and pension claims
- Insurance data
- Bank data (in case benefits are paid out)
- Possibly comparable data of dependants entitled to benefits (in case survivor’s benefits are paid out)
- Log data created when IT systems are used.
These may also include special categories of personal data such as data concerning health.
Sources of the personal data
Your personal data are for the most part transmitted from the respective Vodafone GmbH accounting system on the basis of which your pay is determined and paid out. Further data will be provided directly by you in connection with your company pension claims in the context of the online account or determined by us in connection with the administration of your company pension claims.
Processing purposes and legal bases
Willis Towers Watson GmbH and the Vodafone GmbH companies process your personal data in compliance with the provisions of the EU General Data Protection Regulation (GDPR), national data protection laws and further relevant national laws. Data processing serves to determine and administer your company pension claims resulting from your employment with a legal entity of Vodafone GmbH.
The primary legal basis for this is Article 6 paragraph 1 sentence 1 lit. b GDPR (performance of a contract). Further legal bases are:
- Article 6 paragraph 1 sentence 1 lit. a GDPR ("consent"): in the context of the establishment of your employment relationship;
- Article 6 paragraph 1 sentence 1 lit. f GDPR ("weighing up of interests"): legitimate interest of the controller.
Special categories of data
Insofar as special categories of personal data in the sense of Article 9 paragraph 1 GDPR (e.g. data concerning health) are processed, this will occur on the basis of Article 9 paragraph 2 lit. b. GDPR.
Disclosure of data
Within Willis Towers Watson GmbH and within the respective legal entity of Vodafone GmbH where you are employed, only persons and bodies entrusted with the handling of your company pension claims will be given access to your personal data.
In principle, we will only transmit your personal data to other controllers if and to the extent this is required in order to handle your company pension claims, we or the third party have a legitimate interest in the disclosure, or your consent to this has been obtained. You can find details on the legal bases in the section "Processing purposes and legal bases". Third parties may also be other legal entities of Vodafone GmbH. If data are transmitted to third parties on the basis of a legitimate interest, this is explained in this data protection notice. Furthermore, we may transmit your personal data to other recipients outside Willis Towers Watson GmbH and Vodafone GmbH to the extent this is required in order to fulfil contractual and statutory obligations.
Contractors and service providers (processors)
Where we use service providers, we have selected them carefully and monitor them regularly, especially their careful handling of personal data and the security of the data they store. We require that all service providers commit themselves to confidentiality and compliance with statutory requirements. Service providers may also be other legal entities of Willis Towers Watson GmbH or Vodafone GmbH.
Disclosure to recipients outside the European Economic Area
Should we transmit personal data to contractors, service providers or group companies outside the European Economic Area (EEA), such transmission will only occur if the EU Commission has confirmed that the third country offers an appropriate level of data protection or other appropriate data protection guarantees (e.g. binding internal data protection provisions, or EU standard contractual clauses) are in place.
You can obtain an overview of the recipients in third countries and a copy of the specific rules agreed to ensure the appropriate level of data protection from us. To do so, please use the above-mentioned contact information.
Duration of storage; retention periods
We will delete your personal data as soon as they are no longer required for the above-mentioned purposes or there is no longer a legitimate interest in storage of the data. After the end of your employment, your personal data will be stored for as long as we are obliged to do so due to the continued existence of company pension claims or in accordance with national laws. Personal data may also be retained for the period of time during which claims can be lodged against us or against Vodafone GmbH.
Security of data processing
We will take all necessary technical and organisational measures to ensure an appropriate level of security and to protect your processed data, especially against the risks of accidental or unlawful destruction, manipulation, loss, alteration or unauthorised disclosure or access. Our security measures are continuously improved in line with technological developments.
Rights of the users
To assert your rights, please use the information shown in the contact information section. In so doing, please make sure that we can uniquely identify you.
Right to information and right of access
You have the right to obtain information about the processing of your data from Vodafone GmbH. For this purpose you can assert a right of access with regard to your personal information which we process.
Right to rectification and erasure
You can request the rectification of any inaccurate data and – if the statutory requirements are fulfilled – the completion or erasure of your data from Vodafone GmbH.
This does not apply to data that are required for accounting and bookkeeping purposes or the determination and administration of your company pension claims or that are subject to statutory retention obligations. Insofar as access to such data is not required, their processing will be restricted, however (see below).
Restriction of processing
If the statutory requirements are fulfilled, you can request Vodafone GmbH to have us restrict the processing of your data.
Objection to data processing
In addition, you have the right to object at any time to data processing by Vodafone GmbH. We will then stop processing your data, unless we can demonstrate – in accordance with statutory requirements – compelling legitimate reasons for continued processing that override your rights, especially your rights to object.
Objection to data processing on the legal basis of a "legitimate interest"
In addition, you have the right to object at any time to data processing by Vodafone GmbH insofar as it occurs on the legal basis of a legitimate interest. We will then stop processing your data, unless we can demonstrate – in accordance with statutory requirements – compelling legitimate reasons for continued processing that override your rights, especially your rights to object.
Withdrawal of consentg
If you have consented to the processing of your data, you can withdraw this consent at any time with effect for the future. This will not affect the lawfulness of the processing of your data until the time of withdrawal.
Data portability
You furthermore have the right to receive transmission of the data you have provided to us in a structured, commonly used and machine-readable format and/or to request – insofar as this is technically feasible – that the data be transmitted to another controller.
Right to lodge complaints with the supervisory authority
You have the right to lodge a complaint with a data protection authority. To do so, you can contact the data protection authority that is competent for your place of residence or your federal state, or the data protection authority that is competent for us.
The lead data protection authority for Willis Towers Watson GmbH is the Hessian Data Protection Officer (Hessischer Datenschutzbeauftragter):
Postal address:
Der Hessische Datenschutzbeauftragte
Postfach 3163
65021 Wiesbaden
DEUTSCHLAND
Tel.: +49 611 1408 - 0
Telefax: +49 611 1408 - 611
E-Mail: Poststelle@datenschutz.hessen.de