POLICY ON PROCESSING OF YOUR PERSONAL DATA
Controller : Inchcape Retail Belgium SA
Company number: BE0459491374
Address: Boulevard Industriel 198, 1070 Anderlecht
Hereafter "we" or "us" or "IRB".
- WHAT DATA IS COLLECTED?
Depending on the relationship we have with you, we may collect the following categories of data:
General information, such as
- Your name, first name, title, language and date of birth
- Your postal address, e-mail address, telephone number and/or mobile phone number, ...
- Any personal information that you provide voluntarily and without obligation (e.g. family composition, profession etc);
If you are a professional, corporate information such as
Contact details of your company/association/institution: name, postal address, fixed and/or mobile telephone number, e-mail address, VAT and company number, legal form;
Vehicle-related information, such as
- Information about the interactions you have with us, such as your customer history, transactions including e.g. your visits to our showrooms, purchases, your saved vehicle configurations, your visits to our network for repair and maintenance, questions, requests and complaints;
- Information about your vehicle (e.g. vehicle identification number, information vehicle delivery date, mileage, diagnostic information, information about the maintenance and repairs carried out on your vehicle, and information about the CO2 emissions and energy consumption of your vehicle in actual use);
- The dealer(s) or repairer(s) involved;
- Information related to the connectivity of your vehicle (technical logging etc.);
- Information related to connectivity via applications linked to your vehicle;
- Information about your interests and preferences.
Information related to our surveys
The answers you gave in the survey (unless the survey was anonymous)
Information about the consents you have given to us and our management of those consents (including, for example, record keeping and processing of your withdrawals).
Information from third parties, such as:
We may also collect information about you from public databases, social media platforms or marketing database owners, which will help us to update your Data, improve the quality of your Data or complete your Data, allowing us to better understand the type of products that may be of interest to you.
Where possible, we also keep track of the dates on which this information is provided to us or when changes are made to it.
Automatic Data Collection
Our website uses server logs, which register your interactions with our website and the web pages you visit in relation to the current Internet Protocol (IP) address of your computer. The automated processes we use to collect information are cookies, log files and Wi-Fi access point tags.
- PURPOSES AND LEGAL BASIS FOR PROCESSING YOUR DATA
We process your data for the purposes and on the legal basis described below:
Follow up and answer your enquiries :
- To follow up and respond to your request for a test drive, quotation, brochure, appointment or information on " Build Your Dream " products and services or any other request for information;
Execution of a contract or
legitimate interest pursued by the Controller(s) or a third party
Execution of contracts between you and us:
- To conclude, execute and follow up the contracts that may exist between you and us, for example in the context of the purchase of a vehicle;
- To provide you with our products and services (e.g. maintenance, breakdown and repair of your vehicle, warranty implementation, mobility services, etc.);
- For accounting purposes;
- In order to combat possible fraud, crime and infringements and to ensure the management of possible disputes and legal proceedings;
- To process and transmit your Data in the context of the assignment of claims to a third party;
- To fulfil our obligation to be able to locate you in the event of an accident or distress call;
Execution of a contract
Evaluate and improve the quality of our products, services and customer experience:
- To contact you if your vehicle is part of a safety recall or service campaign;
- To carry out market analyses, financial management or reporting;
- To send you satisfaction surveys to know how you experience the customer relationship and the products and services (no marketing research or marketing content);
- To combat potential fraud, crimes and offences and to manage potential legal disputes and proceedings;
- To evaluate the quality of our products and services;
- To carry out research and development activities;
Legitimate interest pursued by the Controller(s) or a third party
Sending out marketing communications and marketing surveys:
- To send you our marketing communications, through all channels, including social networks;
- To send you reminders with marketing content related to your vehicle and the renewal of services we offer that are about to expire (e.g. service reminders and technical control reminders);
- To send you information and invitations about the events we organize.
- To send you market research surveys and polls with marketing, advertising or promotional content related to our products and services and to your interests, preferences and expectations, and to follow up on your feedback;
- To follow-up on your participation in our competitions;
- To send you newsletters to which you have subscribed;
You can withdraw your consent(s) at any time (see below).
We want to assure you that we will not abuse your consent to spam you, overload you with messages or be intrusive.
What you will receive from us is relevant and useful to you. This information is used to personalise our communications with you and to provide you with personalised offers, advertisements and invitations.
For example, we may review your various interactions with us or, if you agree to receive emails from us, we may check if you open and read them, which helps us to determine what interests you have and helps us to ensure that the information provided to you is the most likely to be of interest to you.
Your consent (provided separately)
Managing your personal data:
- to centralize, combine, share, update and correct your Data that you have provided to us
Legitimate interest pursued by the Controller(s) or a third party
Sharing of your personal data to comply with a legal obligation:
To comply with our legal obligations (e.g. to comply with a court order or an order or request from an authority (police, etc.).
the history of your vehicle may be shared with successive owners in accordance with European legislation. The same applies to the communication to the European Environment Agency and the European Commission of CO2 emission and energy consumption data under conditions of actual use, unless the owner of the vehicle expressly refuses to make this data available to the manufacturer or its authorised dealer or repairer.
In the above cases, the transferred data concerns only vehicle data.
- RETENTION PERIOD OF YOUR DATA
Our policies and procedures use the following criteria to determine the retention periods for Personal Data for the purposes described above:
- The period of time that has elapsed since your last interaction with us;
- The time it takes for us and for you to respond to your request(s).
- For as long as it takes us and you to fulfil your request(s) (for example, if you have requested a driving test, we will retain your personal data for 6 months after the date you send us your request).
- At the end of the contractual relationship with you;
- The existence of an actual or potential dispute or disagreement (e.g. we need this information to bring legal claims or defend against legal claims), in which case we will keep your information until the dispute or disagreement is resolved;
- The existence of a regulatory or legal obligation to retain personal information (e.g. for tax purposes), in which case we will keep your information for as long as such obligation requires.
- RECIPIENTS OF YOUR DATA
Your data is shared with and made accessible to the categories of recipients listed below:
- External subcontractors, in the framework of the services they perform on our behalf (e.g. external call centers, advertising agencies, IT service providers, ...).
- Other entities within our organisation or brand environment, such as other companies belonging to the same group as IRB, among which BYD Europe BV.
- If you have entered into a financing/ loan/leasing agreement or insurance agreement related to your vehicle with with one of our business partners, we will process the relevant information needed to complete the forms relating to the agreement as a subcontractor and will pass it on to the relevant partner, the controller. In this case, we invite you to refer to the privacy notice of the partner concerned.
Transfer of Data outside the European Economic Area:
We may transfer your Data to destinations outside the EEA (eg United States)
In the event that your Data is transferred outside the EEA, we will ensure that your Data is protected by the following safeguards:
- The law of the country to which your data is transferred provides an adequate level of data protection (Article 45 GDPR); or
- The transfer is subject to data protection clauses approved by the European Commission (Article 46 et seq. GDPR).
Your data will not be transferred to the manufacturer in China.
- USE OF SOCIAL NETWORKS
If in the course of our relationship, you use a specific social network login ID (for example, your Facebook account), we will collect your personal data available on that social network, and the use of such social network login ID will constitute your consent to the disclosure of your personal data collected by us in this way.
In certain specific cases (e.g. via use of the "share", "like" or "follow" buttons) we may be considered joint Controllers with Facebook for the collection and processing of your data.
- YOUR CHOICES AND RIGHTS
We want to be as transparent as possible with you, so that you can make informed choices about how you want us to use your personal data.
Your personal data
You can always contact us at the address given at the beginning of the document to find out what personal data we hold about you and where it comes from. Under certain conditions, you have the right to receive your personal data, which you have provided to us, in a machine-readable, commonly used format and to transfer your personal data to a third party of your choice.
Your right of rectification
If you find an error in your personal data or if you notice that it is incomplete or incorrect, you can also ask us to correct or complete it.
Your right to restrict the processing
You have the right to request a restriction on the processing of your personal data (e.g. while the accuracy of your personal data is being verified).
Your right to object / right to be forgotten and right to withdraw consent
You can object to the use of your personal data for direct marketing purposes (if you prefer, you can also tell us through which channel and how often you want us to contact you) or to the sharing of your personal data with a third party for the same purpose.
You may withdraw your consent to the processing of your personal data at any time by contacting us.
In addition, you can ask us to delete your data (except in certain cases, for example to provide proof of a transaction or in the event of a legal obligation).
You also have the right at any time to lodge a complaint with the Data Protection Authority, at the address Rue de la Presse 35, 1000 Brussels, or by e-mail addressed to ‘email@example.com’.