These disclosures supplement the information contained in our Privacy Statement by providing additional information about our personal data processing practices relating to individuals who access our sites and other online platforms or otherwise interact with us from the European Economic Area (“EEA”) and United Kingdom ("UK"). For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Statement.
EEA and UK Representatives
We have appointed the following parties to act as our representatives in the EEA and UK:
Dr Marc Störing
Osborne Clarke Verein
marc.stoering@osborneclarke.com
Margarita Karamitsou
Motorola Solutions
margarita.karamitsou@motorolasolutions.com
Agnieska Podmokly
Motorola Solutions
agnieska.podmokly@motorolasolutions.com
Jose Dias
Motorola Solutions
jose.dias@motorolasolutions.com
Susana Gómez
Motorola Solutions
susana.gomez@motorolasolutions.com
Carole Lawrence
Motorola Solutions
carole.lawrence@motorolasolutions.com
If you choose to contact our EEA or UK representatives, please ensure you reference MSI in any correspondence you send them.
Our Data Protection Officer
We have appointed a Data Protection Officer who is responsible for monitoring our compliance with applicable data protection law. You can contact our Data Protection Officer with any questions or complaints you may have about our privacy practices in the following ways:
Data Protection Officer
Motorola Solutions, Inc.
500 W. Monroe
Chicago, IL USA 60661-3618
United States
Email: privacy1@motorolasolutions.com
Additional Questions or Complaints
If you have a concern about our processing of personal data, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:
We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please contact us directly at privacy1@motorolasolutions.com if you have any concerns.
Purposes and Legal Bases of Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
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Contract: Where the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract with you. This applies to any processing where you sign a contract with us, for example when you become our customer or deliver services to us as a vendor or contractor. This may also include processing necessary for the performance of our Terms of Use.
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Legitimate Interest: Where the processing is necessary for the purposes of a legitimate interest that are not overridden by your interests or fundamental rights and freedoms (e.g., to conduct analytics and communicate with you).
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Vital Interest: Where the processing is necessary to protect the vital interests of you or another person (e.g., to protect your physical safety).
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Public Interest: Where the processing is necessary to perform tasks carried out in the public interest or in the exercise of official authority vested in us (e.g., to cooperate in an ongoing law enforcement investigation).
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Legal Obligation: Where the processing is necessary to comply with our legal obligations (e.g., to maintain a record of your personal data to comply with laws and regulations related to bookkeeping, accounting, taxation, and employment).
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Consent: Where we have your consent for the processing (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw your consent at any time.
You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our offerings. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to fulfill your request. We will inform you at the point that we collect personal data from you if the provision of certain personal data is mandatory or optional.
Automated Decision-Making and Profiling
We do not conduct automated processing of personal data, including profiling, for the purposes of making decisions about you.
Retention of Personal Data
We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.
The criteria used to determine the period of time for which personal data about you will be retained varies depending on the legal basis under which we process your personal data:
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Contract: Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
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Legitimate Interest: Where we are processing personal data based on legitimate interests, we generally will retain the information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.
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Vital Interest: Where we are processing personal data based on vital interests, we generally will retain the information for the period of time necessary to protect the vital interests of the relevant person plus some additional limited period of time that represents any applicable statute of limitations for legal claims that could arise out of the related events.
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Public Interest: Where we are processing personal data to perform tasks carried out in the public interest or in the exercise of official authority vested in us, we generally will retain the information for a reasonable period of time based on the public interest / official authority, taking into account any obligations we may have to retain the information for a longer period of time.
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Legal Obligation: Where we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation plus some additional limited period of time that represents the statute of limitations for legal claims that could arise from the legal obligation.
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Consent: Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the purposes for which you have provided your consent.
In certain circumstances, we may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved. In all cases, in addition to the purposes and legal bases identified above, we consider the amount, nature and sensitivity of personal data, as well as the potential risk of harm from unauthorized use or disclosure of personal data, in determining the relevant retention period.
Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.
International Transfers of Personal Data
We operate and engage third-party partners and providers in various jurisdictions. Therefore, we and our third-party providers may transfer personal data to, or store, access, or process personal data in, a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred.
We may transfer personal data about you outside of the EEA and UK, and when we do so we rely on appropriate or suitable safeguards recognized under applicable law, including adequacy decisions, Standard Contractual Clauses, the EU-US Data Privacy Framework and Binding Corporate Rules. Additionally, data may be transferred outside of the European Union for purposes of litigation, or exercise or defense of legal claims, where otherwise permitted by law. If you would like more information on the specific safeguards we use (and to obtain a copy of such safeguards, where applicable), please contact us at privacy1@motorolasolutions.com.
Adequacy Decisions
We may transfer personal data about you to countries that the relevant regulatory authority have deemed to adequately safeguard personal data, either automatically or in connection with a specific safe harbor framework.
Standard Contractual Clauses
Certain regulatory authorities have adopted Standard Contractual Clauses, which provide safeguards for personal data transferred outside of the originating jurisdiction. We may use these Standard Contractual Clauses when transferring personal data to a third country that has not been deemed to adequately safeguard personal data.
EU-U.S. Data Privacy Framework
The EU-U.S. Data Privacy Framework was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for personal data transferred to a company participating in the EU-U.S. Data Privacy Framework. If we transfer any personal data about you from the EEA to a third party outside the EEA who is participating in the EU-U.S. Data Privacy Framework, we may rely on their participation in the Framework to ensure adequate protection for personal data so transferred.
Binding Corporate Rules
We have adopted a set of Binding Corporate Rules - Controller ("BCR-C’s"), for the EEA, effective October 12, 2020, and the UK, effective May 2, 2013. The BCR-C’s are designed to ensure that personal data of covered individuals in the EEA and UK are protected while being processed by any of our affiliates around the world. As a result, we rely on the BCR-C’s when transferring personal data within MSI.
The Danish Data Protection Agency, Datatilsynet approved our EEA BCR-C’s. For the full text of our EEA BCR-C’s, click here. For a link to the BCR-C’s appendices, click here.
The Information Commissioner’s Office (“ICO”) approved our UK BCR-C’s. For the full text of our UK BCR-C’s, click here. For a link to the BCR-C’s appendices, click here.
Your Additional EEA, UK, and Swiss Privacy Choices
Individuals whose personal data is collected and/or used in the EEA or UK have the rights described in our BCR-C’s (available above). In addition, subject to certain limitations at law, you may be able to exercise the following rights:
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Right to Access: The right to obtain confirmation of whether we are processing personal data about you, access to and a copy of the personal data we are processing about you, and information relating to its processing, including:
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The categories of personal data being processed;
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The purposes of the processing;
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The categories of the sources of the personal data;
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The categories of recipients to whom the personal data have been or will be disclosed;
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The envisaged period for which the personal data will be stored, or the criteria used to determine that period;
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Any automated decision-making or profiling performed in connection with your personal data; and
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The safeguards relied upon for the transfer of personal data to any third country.
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Right of Portability: The right to obtain a copy of the personal data we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal data to another controller without hindrance.
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Right to Rectification: The right to correct or update any personal data about you that is inaccurate or incomplete.
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Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
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Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal data. Please note withdrawing your consent will not affect the lawfulness of our use of your personal data before your consent was withdrawn, nor our processing of personal data pursuant to a different lawful basis for processing.
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Right to Erasure: The right to have us erase your personal data if the continued processing of that personal data is not otherwise justified.
Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our services to you, or otherwise engage with you in the same manner.
Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by completing our online form found here.
To exercise your right to object as it relates to the use of cookies and related technologies that facilitate our online targeted advertising activities on the www.motorolasolutions.com site, please click here to open our homepage, scroll to the bottom of the page, click “Cookie Preferences” in the footer of the website, and adjust your preferences accordingly. Where available, you may adjust your cookie preferences on our other websites through similar cookie preference managers. Please note these opt-out tools are website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you may follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Statement to further exercise control over automatic data collection technologies.
Before processing your request to exercise certain rights (taking into account the confidential nature of any personal data we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form and toll-free number to include first and last name, email address, state of residency and data request.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal data or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA or UK.