Dana Incorporated: Careers Privacy Notice

Effective Date: 25 May 2018

Dana Incorporated (“Dana”, "we" or "our") respects your concerns about privacy.  This Careers Privacy Notice describes the types of Personal Data we collect on the Careers pages of www.dana.com (the “Careers Site” or "our Website"), how we and the respective local EU based Dana subsidiary you apply to via the Careers Site (the "Local Dana Entity") use the information and with whom we and the Local Dana Entity may share it.  This Careers Privacy Notice also describes the measures we and the Local Dana Entity take to safeguard the Personal Data, the statutory rights you have regarding your Personal Data and how you can contact us and the Local Dana Entities about our privacy practices.  Further, this Careers Privacy Policy describes our use of cookies and similar technologies on the Careers Site. This Careers Privacy Notice does not apply more broadly to the www.dana.com website, which is subject to its own privacy notice that can be found at here.

For the purposes of this Careers Privacy Notice "Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

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Personal Data We Collect
We collect Personal Data (a.) directly from you when you submit information via the Careers Site, (b.) automatically in the course of your use of the Careers Site and (c.) from third parties, including commercially available sources, such as public databases (where permitted by law).

a. Personal Data we collect directly from you
The Personal Data that we and/or the Local Dana Entity collect directly from you when you submit information via the Careers Site, e.g. when you create and manage an account for the Careers Site or submit the requested information via the application forms provided on the Careers Site, in particular the "Apply for job" form and the "Student Profile Form", include the following Personal Data:

  • Contact information (such as first name, middle name, last name, telephone number, postal address and email address)
  • Login credentials to access the Careers Site
  • Citizenship and work authorization status
  • Education history
  • Employment and salary history
  • Resume or C.V.
  • Language proficiency
  • Information about your relationship with Dana
  • Other information about your qualifications

If you apply for a U.S.-based position, you may provide information on your gender, race or ethnicity on a voluntary basis.  Dana will not consider either this information or your choice to decline to provide it in evaluating your qualifications for employment with us.  We may use this information to the extent necessary or appropriate for compliance with relevant legal or contractual obligations and for other internal purposes. 

Further information may be required by the Local Dana Entity to which you apply in accordance with local law requirements.

b. Information we automatically collect from you by means of cookies

In addition, when you visit the Careers Site, we may collect certain information, including Personal Data, by automated means, such as cookies, web server logs and web beacons.  For further details on what information, including Personal Data, we collect by such means and how we use it please see below under section 3. 

c. Personal Data we collect from third parties 

During the application process, we and/or the Local Dana Entity may obtain certain information from third party sources such as online searches, social media for business professionals and recruiting agencies.  The collection of such data (if any) will be conducted in compliance with the laws applicable to us or the Local Dana Entity.

How We and the Local Dana Entity Use the Personal Data We Collect and the Basis On Which We and the Local Dana Entity Use It
We and the Local Dana Entity use the Personal Data collected directly from you (see above section 1.a.) to:
  • Provide applicant support and respond to and communicate with you about your requests, questions and comments to allow us and/or the Local Dana Entity to take steps at your request prior to potentially entering into an employment contract with you. 
  • Establish and manage your Careers Site account to allow us to comply with our contractual obligations towards you.
  • Evaluate you for available positions to allow us and/or the Local Dana Entity to take steps at your request prior to potentially entering into an employment contract with you.
  • Collect background check information to allow us and the Local Dana Entity to pursue our/its legitimate interests in conducting background checks on applicants, in particular in order to verify the information provided by the applicant in his/her application, and, where applicable, to comply with legal obligations. 
  • Contact you regarding possible employment to allow us  and/or the Local Dana Entity to take steps at your request prior to potentially entering into an employment contract with you. 
  • Analyze the information collected by us to facilitate the application process. 
  • Pursue our and/or the Local Dana Entity's legitimate interests in protecting against, identifying and preventing fraud and other possible criminal activity, claims and other liabilities. 
  • Comply with applicable legal requirements and internal requirements concerning the hiring process.
We and the Local Dana Entity also may use the information in other ways for which we provide specific notice at the time of collection.  

You are neither contractually nor legally obliged to provide your Personal Data indicated under sections 1. a., b. and 3. However, if you do not provide your Personal Data, it may not be possible for us to continue the application process or to process other requests you may submit via the Careers Site or for you to use all functions of the Website. 

Cookies
When you visit the Careers Site, we collect certain information, including Personal Data, by automated means, such as cookies, web server logs and web beacons (hereafter jointly referred to also as "Cookies").  

The information collected in this manner may include, in particular, IP addresses, operating systems type, browser type, domain and other system settings.  

A “Cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.  A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and their Cookies and may be used to transmit information collected through Cookies back to a web server.  Through these automated collection methods, we collect “clickstream data,” which is a log of content on which a visitor clicks while browsing a website.  As the visitor clicks through the website, a record of the action may be collected and stored.  Your browser may tell you how to be notified when you receive certain types of Cookies or how to restrict or disable certain types of cookies.  Please note, however, that without Cookies you may not be able to use all of the features of our website.  Our Careers Site is not designed to respond to “do not track” signals received from browsers.

a. Essential Cookies

Except as indicated otherwise in this Careers Privacy Notice, the Cookies used by us are essential for the functioning and performance of the Careers Site, such as by making the Careers Site more efficiently and facilitating your use of the functionalities and services provided; these functionality and/or performance Cookies will be deleted from your device within 24 hours once your browser-session has ended (session Cookies). We will not use the information stored in essential Cookies for any other purpose than as strictly necessary to provide you with the services and functionalities requested.

b. Google Analytics

This Website uses Google Universal Analytics ("Google Analytics"), a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies to help us analyze how users use our Website, including the number of visitors to our Website, the websites our visitors have come from, and the pages they visit. This information is used by us to improve our Website offer and services. As a rule, any information generated by the cookie about your use of our Website will be transmitted to and stored by Google on servers in the United States. As the IP anonymization is activated on our Website, Google will anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area.  Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA.

Google will use this information as our commissioned data processor to help us evaluate the use of our Website, to compile reports on website activity and to provide other statistical and analytical services relating to usage of our Website. The IP address transmitted by your browser within the framework of Google Analytics will not be associated with any other data held by Google. The information will be stored for a period of 14 months, after the end of this period it will be automatically deleted.  

You may prevent the collection of data generated by the Cookie about your use of this Website (including your IP address) and opt-out of being tracked by Google Analytics across all websites by downloading and installing a browser-plugin which is available here.

As an alternative to installing the browser-plugin, or in case you use our Website with browsers on mobile devices, you can also opt-out of being tracked by Google Analytics if you click on the following opt-out link: Opt-out of Google Analytics Tracking 

In this case, an opt-out Cookie will be placed on your browser that prevents any further tracking of your use of this Website by Google Analytics. Please remember that you will have to opt-out again if you delete all Cookies stored on your device. You will also have to opt-out for each device you use to visit our Website.

c. Internet-Based Advertising 

On the Careers Site, Dana may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests.  This section of the Careers Privacy Notice provides details and explains how to exercise your choices.

You may see certain ads on other websites because Dana participates in advertising networks.  Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means.  These networks track your online activities over time by collecting information through automated means, including through the use of Cookies, web server logs and web beacons.  The networks use this information to show you advertisements that may be tailored to your individual interests.  The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites.  This data collection takes place both on the Careers Site and on third-party websites that participate in the ad networks.  This process also helps us track the effectiveness of our marketing efforts.  To learn about how to opt out of this ad network interest-based advertising, click here.

Sharing of Personal data
We do not sell or otherwise disclose Personal Data we collect about you, except as described in this Careers Privacy Notice.  

We may share your Personal Data with the Local Dana Entity with the vacancy you apply for via the Careers Site for the purpose of the application process; by clicking here you find a full list with the Local Entities, including contact information, you may apply for via the Careers Site.

Further, we and the Local Dana Entity may share your Personal Data with our service providers who perform services and other business operations in the field of IT application, recruiting and human resources management for us for the purposes set out above. These services providers are located in the United States and/or the jurisdiction of the Local Dana Entity..

We and the Local Dana Entity also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.  We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). 

International Data Transfers
The recipients we and the Local Dana Entity share your Personal Data with (as described in the section above) may be located in a country that is not regarded as providing the same level of protection for Personal Data as provided by the data protection laws applicable to the processing of your Personal Data by Dana according to this Careers Privacy Notice, in particular EU data protection laws. We and the Local Dana Entity have put in place appropriate safeguards (such as EU standard contractual clauses) in accordance with applicable legal requirements to provide adequate protections for your Personal Data. For more information on the appropriate safeguards in place and to collect a copy of such safeguards, please contact us or the Local Dana Entities at the contact information set forth below under section 10.  

Automated Decisions About You 
Neither Dana nor any Local Dana Entity do carry out any decision making based solely on automated processing of Personal Data collected under this Careers Privacy Notice, including profiling.

Your Rights Regarding Your Personal Data 
Subject to applicable statutory data protection laws, you may have the right vis-à-vis Dana and the Local Dana Entity: 
  • to access your Personal Data as well as to collect a copy of such Personal Data (right of access); 
  • to have inaccurate Personal Data rectified and, taking into account the purpose of the processing, supplement incomplete Personal Data concerning you (right of rectification);  
  • to have your Personal Data erased to the extent permitted by applicable data protection law (right to erasure; "right to be forgotten"); 
  • to restrict processing of your Personal Data to the extent permitted by law (right to restriction of processing); and
  • to receive Personal Data which you have provided to Dana in a structured, commonly used and machine-readable format and to transmit such Personal Data to another controller without restriction by Dana and, where technically feasible, to have such data transmitted directly from Dana to another controller to the extent permitted by law (right to data portability).   
Further, according to applicable statutory data protection laws, you have the right to object, on grounds relating to your particular situation, to the processing of your Personal Data to the extent permitted by law. If your personal data were to be processed by us or any Local Dana Entity for direct marketing purposes - which is currently neither done nor planned - you can object to the processing for the purpose of such marketing in any case (right to object). 

Where you have given your consent for the processing of your Personal Data you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before it has been withdrawn. 

In order to exercise your rights, you may use the contact details set out below under section 10. In addition and without prejudice to any other rights, you have the right to lodge a complaint with a supervisory authority.    

We encourage you to contact us at the contact information set forth below to update or correct your Persona Data if it changes or if the Personal Data we hold about you is inaccurate. 
Please note that we may require additional information from you in order to honor your requests. 
If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below under section 10. 

How We and the Local Dana Entity Protect Personal Data and For How Long It Is Stored 

We and the Local Dana Entity maintain administrative, technical and physical safeguards designed to protect your Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.  

We and the Local Dana Entity store your Personal Data as long as necessary for purposes indicated in this Careers Privacy Notice, in particular: We and the Local Dana Entity store your Personal Data as long as necessary for the application process, and, after the end of the application process, as long as necessary to investigate or defend against potential legal claims; if we or the Local Dana Entity keep your Personal Data for longer in order to contact you regarding new vacancies that you might be interested in, we will ask you to provide your prior consent.  We store the Personal Data you have submitted in order to create and manage your Careers Site account until you delete your Careers Site account. 

Links to Other Websites 

Our Careers Site may contain links to other websites for your convenience and information.  These websites may be operated by companies not affiliated with Dana.  Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites.  We are not responsible for the content of any websites that are not affiliated with Dana, any use of those websites, or the privacy practices of those websites.

How To Contact Us 

Dana is the controller responsible for all Personal Data we collect via the Careers Site.  We are represented in the EU by Dana Investment GmbH, Reinzstrasse 3-7, 89233 Neu Ulm, Germany.

The Dana Local Entity is the controller for the Personal Data received from Dana which we have collected through the Careers Site and shared with the Dana Local Entity as described in this Careers Privacy Policy.  

If you have any questions or concerns regarding the way in which we and/or the Local Dana Entity processes your Personal Data or questions or comments about this Careers Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact Rashad Delph or our representative in the EU by email at marc.schuett@dana.com or the Local Dana Entity at the contact information provided the list linked under section 4. 

You also may write to us at:
Dana Incorporated
HR Shared Services
3939 Technology Drive
Maumee, Ohio
43537 USA

Changes to this Careers Privacy Notice
We may modify or update this Careers Privacy Notice from time to time. If we make any revisions that materially change the ways in which we process your Personal Data, we will notify you of these changes before applying them to that Personal Data.