We understand your concerns regarding the confidentiality of your personal information. Below is a description of how we acquire and use that information and an outline of your rights. Please read this carefully, so that the process may be as fair, transparent and secure as possible.
The following principles are essential to how we process your personal information:
· Transparency and fairness: When we collect and process your personal information, we inform you as to who collects and receives these data, and the reasons for this. When required by law, we always seek your prior consent (i.e. before collecting any sensitive information or sending any direct marketing material (newsletters), apart from and independently from information on contract performance). We never use your personal information for purposes that are non-compliant with the purposes outlined here.
· Legitimacy: ALD Automotive Ltd. does not collect or process personal information without a lawful reason. We use your personal information only for appropriate business purposes (e.g. to provide services, manage relationships with customers, manage customer vehicle fleets, managing financial relations with customers, for marketing activities towards customers, profiling to provide better services to customers, to conduct satisfaction surveys or draft reports and comply with our legal obligations).
· Minimization: We only collect the personal information strictly necessary for data processing, as set out in this document. We collect sensitive information only where relevant. We take all reasonable measures to ensure that your stored personal data is accurate, complete and up-to-date.
· Privacy: We endeavor to ensure privacy when implementing personal data processing. To this end, we also carry out privacy impact assessments to ensure that our safety measures are appropriate and that your data is protected.
How long do we keep your personal data?
We retain your personal data only throughout the duration of the business relationship with ALD Automotive, or during a certain time period since our last contact, as required by local legislation or in order to comply with regulatory obligations of ALD Automotive Ltd.
In case of litigation before the competent public authority, we may keep your personal data until the end of such legal action, including any potential periods for appeal. We will then either delete or archive it according to the law in force.
In any event, your personal data will not be kept by ALD Automotive Ltd. in a form that allows you to be identified any longer than necessary for achieving the purposes for which it was collected or processed, or according to the relevant laws in force.
How do we ensure the security and integrity of your personal data?
We protect your data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing by applying technical and organizational security measures (including education and training of relevant personnel).
Your data can be accessed only by those teams and employees within our company who need to have access to the data. We make sure to implement administration rights and policies within our company, and we take all measures to ensure that our employees, advisers and service providers keep your data confidential.
How can you express your preferences on the use of your personal data?
To exercise the rights set out in the following section at any time, please contact the Data Protection Officer of ALD Automotive Ltd., who will handle your request, via e-mail address: GDPRzastitapodataka@aldautomotive.com.
Withdrawal. In cases where you have given your previous consent for your data to be processed, you can withdraw that consent any moment.
Access. You can request access to your personal data that we keep. If you make such a request, we will provide you with all the information on the purposes of the processing, categories of data processed, categories of recipients, data retention periods, your rights to rectify, delete or restrict the data accessed if applicable, etc.
Portability. You can also obtain a copy of any personal data that we hold about you in our records in a format compatible and structured to allow you to exercise your right to data portability.
Restriction. You can request a restriction of data processing in the following cases:
· for a period enabling ALD Automotive Ltd. to verify the accuracy of your personal data in the event that you contest the accuracy of your personal data;
· if the processing is unlawful and you wish to restrict your personal data rather than deleting it;
· if you wish that ALD Automotive Ltd. keeps your personal data because you need it for your defense in the context of legal claims;
· if you have objected to the processing but ALD Automotive Ltd. needs to check whether it has legitimate grounds for such processing which may override your own rights.
Rectification / Erasure. You may also request that we correct, amend or erase any information which is incomplete, out of date or inaccurate.
You may request the deletion of your personal data in the following cases:
· if your personal data is no longer necessary for the purpose of the data processing;
· if you have withdrawn your consent for data processing based exclusively on such consent;
· if you objected to the data processing;
· if the personal data must be erased to comply with a legal obligations applicable to ALD Automotive Ltd. When it comes to such deletion, we will take reasonable steps to inform other entities within ALD and SOCIETE GENERALE Group which might be involved in the data processing of such erasure.
Objection. You can also object to the processing of your personal data at any time when the data is used for marketing purposes or profiling to send you targeted advertising or to object to the sharing of your data with third parties or within ALD and SOCIETE GENERALE Group.
Complaint. You also have the right to lodge a complaint with the competent supervisory authority.
You can also give your instructions regarding the storage, deletion or disclosure of your personal information after your death. Such instructions may be general or specific.
Specific conditions concerning protection of your personal data
Which activities and persons are concerned by data collection?
This Policy applies to all sources of data globally collected by ALD and SOCIETE GENERALE Group, and processed by ALD Automotive Ltd. in the context of various ALD and SOCIETE GENERALE Group activities such as corporate car leasing, private car leasing, sales locations, third-party sources, usage of our websites or mobile applications and all offline processing activities.
We may collect and process your personal data if you can be classified within any of the following categories:
1. human resources of ALD Automotive Ltd. and human resources within ALD and SOCIETE GENERALE Group,
2. ALD Automotive Ltd. customers and ALD and SOCIETE GENERALE Group customers
- all other persons within the customer system engaged in performance of leasing services defined by the contract, such as:
· drivers of vehicles leased to our contractual partners
· vehicle fleet managers
- beneficial owners of customers – legal entities
- persons who hold management and property rights in customers – legal entities,
3. potential customers,
5. product and service providers (jointly: suppliers), in realization of legal and business leasing relationship.
Who controls the data?
In the Republic of Croatia, ALD Automotive Ltd. performs the data processing activities described above. This section applies to the processing of your personal data by ALD Automotive Ltd. as data controller.
How do we use your personal data?
ALD Automotive Ltd. uses your personal data for improvement of quality of services and fulfillment of obligations under the leasing contract.
Therefore, ALD Automotive Ltd. may use your personal data in the following cases:
a) When necessary for the purpose of contract performance
(i) on a general level, to manage the commercial relationship with you and your company, respond to estimation requests, open customer accounts, complete your orders for services and related activities, proofing fulfillment of ordered services and related activities, manage events, send you notifications related to your contract, respond to your inquiries and requests for verification, provide customer services, account management, support and related training of our personnel involved in such activities, and to provide other services related to you;
(ii) for white-label partners: for fleet management services with reports and widgets, for key accounts, call center assistance and follow-up of international key customers fleets;
(iii) to provide customer satisfaction surveys for professional traders regarding the remarketing of leased cars service via the online platform for advertising used cars under expiring leasing contracts;
(iv) for the purposes of management reporting within ALD Automotive Ltd. and ALD and SOCIETE GENERALE Group on: Sales, Procurement, Finance & Risk, Pricing, Insurance;
(v) to perform regulatory reporting to competent public authorities, in accordance with the national laws in force;
(vi) to provide drivers with car status monitoring applications (e.g. Ecodrive) or provide managers with fleet tracking tools;
(vii) to report the customer satisfaction survey results .
(b) With your awareness and consent
(i) Marketing purposes (subject to your consent when applicable): we may use your data to contact you about new offers or services and special offers that we think you may find valuable, or to send you marketing communications; we may analyze your client profile and preferences and perform multichannel marketing campaigns via automated tools, contact you via SMS or e-mail, or send you brochures;
(ii) Customer satisfaction: based on targeted marketing tools and analyses, we may send you qualitative surveys for our products and services;
(iii) We may also invite you to participate in marketing events, games or quizzes through our mobile applications and/or web sites;
This information helps us to enhance our websites and apps and better understand which products and services you would prefer.
We may install functional cookies to facilitate your visit to our websites or apps, but you can express your preferences regarding cookies used for targeting advertising based on user behavior through the privacy settings options of your browser, which should include features to prevent data being stored on the terminal or the processing of data already stored on such terminal, unless you turn on the feature to allow such storage or processing.
(v) Profiling: to improve our understanding of your interests and concerns: Your personal data may be used for improvement of our website and products, to customize your experience to your needs and to tailor our marketing activities in a way to fit your needs and interests. We believe that it is also in our interest to provide you with a better service and to respond to your needs when required under regulatory obligations;
(vi) to perform customer screening, credit ability checking and Know Your Client (KYC) principle in the context of white-label partnerships; to perform customer rating;
(vii) we use your personal data to maintain business records for legal, administrative and audit purposes.
What types of personal data do we collect?
What types of personal data do we collect?
We collect the following types of personal data:
· Identification and contact data, such as your name, surname, identification number, city, telephone/mobile number or e-mail address;
· Professional data, such as your job title or company address;
· Financial/credit information, such as your credit acceptance date or contract information;
· Private details: such as your gender, date of birth, nationality, language(s), or personal preferences (habits, favorite car, etc.);
· Your voice when you call ALD Automotive Ltd. customer service since your call may be recorded;
· Data on the driver, such as the number/copy of the driver's license or the driver identification code;
We may also collect information about you indirectly from our business partners or social media platforms.
We collect your personal data either directly from you (i.e., if you create an account on one of our sites or make a purchase), or passively (i.e., when using tracking tools like browser cookies) or from third parties (i.e. through social media platforms).
Cookies and other tracking tools
In order to provide you with a better experience when you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tool, server logs and web beacons (e.g. Google Analytics).
If you use our websites, we may collect information about the browser that you use and your browsing behavior.
If you use our mobile app, we may collect your GPS location data, subject to your consent when required. We might also track the frequency of your use of the application, and where you downloaded it.
When your company uses our car leasing services, we may collect data on the vehicle (such as the vehicle registration plate, mileage or last technical examination) and the driver's behavior (such as the average speed), in order to provide services in accordance with the leasing contract.
Who do we share your personal data with?
We understand that you do not want us to provide your personal data directly to third parties for their own marketing purposes without your consent. However, we occasionally need to cooperate with partners or processors to be able to provide you with the requested services and a better experience for the purposes described above. We therefore limit our sharing of your personal data on a need-to-know basis, as follows:
· with internal business departments such as the Sales and Marketing department, Operations department and Accounting and Finance department. Within ALD and SOCIETE GENERALE Group we may share your personal data with other ALD and SOCIETE GENERALE Group entities, who may use your personal information only in accordance with this Policy;
· with our service providers, such as web data lease providers, call centers, data administrators located in the Republic of Croatia, France or within the European Economic Area, who are instructed to use your personal data only in accordance with our instructions;
· with unaffiliated marketing partners, but only with your consent;
· when necessary for sale purposes or transfer of business assets, in connection with a bankruptcy proceeding, to enforce our rights, protect our property, or protect the rights, property or safety of others, or if necessary as support to external audit, compliance and corporate governance functions.
· when required to do so by law, such as in response to a subpoena, including enforcement agencies and courts in the countries where we operate.
Please note that we may also use and disclose personal information about you that is not personally identifiable i.e. personal information in an aggregate form that no longer identifies you.
How is your personal data transferred?
Some of the countries which receive or have access to your data may not provide the same level of data protection as the Republic of Croatia, as the state where the registered seat of ALD Automotive Ltd. is, and the state where you provided your data. You may obtain a list of these countries by contacting the Data Protection Officer of ALD Automotive Ltd. via e-mail, on e-mail address: GDPRzastitapodataka@aldautomotive.com.
Your data may be transferred, stored and processed in any country or territory of one or more affiliated companies which are located outside of the European Economic Area, for the purpose of managing customer relationship at the global level of ALD and SOCIETE GENERALE Group (which ALD Automotive Ltd. is part of), by providing unified car lease services with a globalized car fleet.
In addition to this, we may also transfer your personal data to the service providers involved in the provision of call center services (located in countries outside the European Economic Area), web data lease providers, support and maintenance services (located in countries outside the European Economic Area), or the provision of any other tool used for the processing of personal data of our customers or potential customers.
When we transfer your data to data recipients in those countries, we protect and provide adequate protection for the transfer of your personal information by entering into data transfer agreements with such recipients which is congruent to the European Commission standard clauses.
How long do we keep your personal data?
We retain your personal data collected for the purposes and under the conditions described above for a duration strictly limited to the necessary period.
How can you contact us or the supervisory authority in order to lodge a complaint?
ALD Automotive Ltd.
“Reference: for the Data Protection Officer”
10010 Zagreb, Veliko Polje, Betinska 1
or by sending an e-mail to: GDPRzastitapodataka@aldautomotive.com.
You can also lodge a complaint with the supervisory authority of the country where you are located in case of any concern about processing of your personal information by ALD Automotive Ltd.
In the Republic of Croatia, the relevant supervisory authority is the Croatian Personal Data Protection Agency.