ALD Automotive and privacy

ALD Magyarország Kft. is a provider of mobility services, including operational vehicle leasing, fleet management and remarketing activities. This privacy policy explains our practices regarding the personal data of users of our aldcarmarket.com ("you").

We respect your privacy and therefore we process your personal data in accordance with the General Data Protection Regulation ("GDPR"), other applicable laws and regulations in the field of data privacy, personal data protection and this Privacy Policy.

1. General principles

ALD Magyarország Kft. understands your concerns regarding the confidentiality of your personal information. Below we describe how we acquire and use that information and outline your rights. Please read this carefully, so that the process is as fair, transparent and secure as possible.

The following principles are central 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 (e.g. before collecting any sensitive information or sending any direct marketing material). We never use your personal information for purposes that are incompatible with the purposes outlined here.
Legitimacy: ALD Magyarország Kft. 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, and perform accurate invoicing, or for marketing activities, profiling to better serve 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 personal data on record 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 safeguards are appropriate and that your information is protected.

2. About us

ALD Magyarország Kft. is the data controller of your personal data.

Our contact details :

Budapest, Postafiók 45.1441

You can reach our data protection officer via: hasznaltauto@aldautomotive.com (local DPO email address)

3. How we use your personal data and which personal data is used

PROCESSING	LEGAL BASIS	DATA SUBJECTS CONCERNED	DATA COLLECTED
Assessment and identification of the customer in order to conclude a sales contract	legitimate interest	chief executive officers	Identity document of the chief executive officers; KBIS certificate
Management and administration of the use of the Portal, the contractual relationship and the organization and conduct of the sales process with car dealers and traders, including sending notifications (B2B)	Performance of contract and legitimate interest	chief executive officers	Surname; first name; position; e-mail address; phone and mobile number ID Card company rep employee and/or ID company rep ; Power of attorney with signature

Anti-money laundering and fighting against the financing of terrorism, prevention of bribery, sanctions customer identification, risk analysis and compliance testing	Legitimate interest and Legal obligation	chief executive officers; Company members; UBO; individual customers	Name; First name of the chief executive officers; Identity document; KBIS certificate • Full name (given names and surname); • Function title; • Place and date of birth; • Complete residential address; Screening results
PROCESSING	LEGAL BASIS	DATA SUBJECTS CONCERNED	DATA COLLECTED
Marketing or promotional activities ; Sending newsletters, surveys, or satisfaction polls	Consent	Customers Traders	Name; First name; Postal address; E-mail address; Telephone number
Pick-Up Services	Contract	Drivers	Name of the driver ; address and postal code of the driver's pick up address ; driver's phone number ; driver's email address
Fulfilling the sales contracts and the legal obligation related to the sales Driver's handover of the Vehicle	Performance of Contract	Drivers	Name of the driver ; Driver's phone number ; Driver's email address
Sales via the auction platform to traders (i.e. legal persons or companies)	Performance of Contract	Natural person acting on behalf of their business ; (pseudo-) UBO(s) ; Director(s) and, if applicable, Counterparty Representatives	Full name (given names and surname);; Residential private address ; Place and date of birth ; Identification number ; / For director(s) and counterparty Representatives : Full name (given names and surname); ; Function title ; Place and date of birth ; Complete residential address
Defleeting	Legal obligation	Drivers	Vehicule ; papers of the vehicule
Price setting	Legitimate interest	contact person at a garage	Name ; Professional telephone number ; Professional email address
Refurbishment of the vehicle	Contract	drivers	deleting of personal data contained in the car
Retail (B2C and small B2B)	Contract	individuals, small companies	Individuals : ID card and address proof, driving license and the tax number/tax identification number Companies : Kbis Extract

4. How long do we keep your personal information

Personal data is kept by ALD Magyarország Kft., in an active base, for the time necessary to achieve the objective pursued at the time of their collection.

The retention period is therefore initially set by ALD Magyarország Kft. according to the operational needs necessary for the execution of each sales contract and taking into consideration any recommendations of the local Data protection authority.

The retention period of the data processed for the purpose of management and administration of the use of the Portal, the contractual relationship and the organization and conduct of the sales process with traders, including sending notifications is 30 days from the termination of access to the Portal:

The retention period of the data processed for the purpose of anti-money laundering and fighting against the financing of terrorism, prevention of bribery, sanctions, customer identification, risk analysis and compliance testing is 15 days after identification.

The retention period of the data processed for the purpose of fulfilling the sales contracts and the legal obligation related to the sales is until the lapse of the possibility to enforce the rights and obligations (including accounting and financial obligations) arising from the sales following the completion of the sales transaction and the administration of the transport administration authority.

However, certain longer retention periods may result from legislative and regulatory texts. Some laws also require that documents/information containing personal data be retained for a specific period of time for evidentiary purposes or in anticipation of possible litigation until the action in question is time-barred. For example, in commercial matters for accountability documents, obligations are in principle prescribed by five years if they are not subject to special prescriptions. ALD is therefore obliged to keep certain personal data beyond the execution of the sales contracts, even though it no longer has any use for them, in the form of so-called intermediate archives.

At the end of these periods, the personal data is:

Anonymized; and/or
Purged

5. Who ALD Magyarország Kft. may share your personal data with

In principle, we do not share your data with third parties. However, as part of the execution of the sales contract, we may share company information and personal data with ALD’s affiliates/ SG Group in order to streamline the KYC process.

6. Export of personal data outside of the EEA

In general, all of the ALD databases are located inside the European Union. However, ALD may transfer your personal data from the Europe to countries within or outside the European Economic Area. The countries outside of the EEA may not provide the same level of protection as is available in the EEA. If we transfer your personal data outside the EEA, we will ensure that adequate levels of protection are in place in relation to the processing of your personal data. Hence, ALD will before transferring your personal data outside Europe make sure to implement a Standard Contractual Clauses (SCC). This applies to our support team based in India (SGGSC).

7. Your rights

In order to protect data subjects concerned by the processing of personal data, the GDPR has implemented rights. The rights in question are as follows:

Data subject Right	Description of the right	GDPR Article
Right of access	You can obtain information relating to the processing of your personal data, and a copy of such personal data.	Article 15
Right to rectification	When you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly	Article 16
Right to erasure (right to be forgotten)	You can require the deletion of your personal data, to the extent permitted by the law	Article 17
Right to restriction of processing	You can request a restriction on the use of your personal information	Article 18
Right to data portability	Where legally applicable, you have the right to have the personal data you have provided to us be returned to you in an intelligible format.	Article 20
Right to object	You can object to the processing of your personal data, on grounds relating to your particular situation.	Article 21

Your rights in relation to data processing, the enforcement thereof and the possibilities of legal remedies are set out in articles 15-22 and articles 77 and 79 of the GDPR.

In Hungary, the data protection supervisory authority: National Data Protection and Freedom of Information Authority (1055 Budapest, Falk Miksa u. 9-11, ugyfelszolgalat@naih.hu).

Judicial process: data protection litigation falls within the jurisdiction of the tribunal. The lawsuit may also be instituted before the court of your place of residence or stay, at your choice.

8. Security and data storage

ALD Magyarország Kft. protects your data through technical and organizational security measures, including :

- Up-to-date policies and work instructions and regular verification of compliance;

- Segregation of duties and roles, so that our employees only have access to your personal data if it is necessary for their function and role;

- Effective training of our employees on the rules, issues and risks involved;

- Physical security of the premises where we process your personal data (e.g. access control and video surveillance cameras);

- Numerous IT security measures (secure servers, firewalls and encryption).

Only those teams and employees who need to know your information within our company can access it. ALD Magyarország Kft. make sure to implement administration rights and policies within our company, and we take all measures to ensure that employees, advisers and service providers keep your files confidential.

9. Cookies Policy & Websites

ALD Magyarország Kft. may collect data via cookies to improve the user's browsing experience. Cookies are used, among other tracers, to store preferences and settings in order to save time, enable login, combat fraud, analyze the performance of the website and the services provided by the renter, and compile visit statistics.

If you use our mobile app, we may collect your GPS location, subject to your consent when required. We might also look at how often you use the app and where you downloaded it.

For more details you can consult our Cookie policy by following this link:

https://www.aldcarmarket.com/cookiepolicy/

10. Updates of this Privacy Policy

We may modify this Privacy Policy periodically to be compliant with any new regulations, so please review it regularly. If we change this Privacy Policy, we shall notify you by means of providing a notice on our website homepage. This Notice was last amended on April 15^th 2022.

11. How to contact us

To exercise the rights set out in the article 10 at any time, please send us a letter or an email to the following address ALD Magyarország Kft., address : 1441 Budapest, Postafiók 45.or contact your local ALD Data Protection Officer through hasznaltauto@aldautomotive.com, and we will handle your request.