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ALD Automotive and privacy

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ALD Automotive AB 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 Automotive 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 Automotive 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, 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 Automotive AB is the data controller of your personal data.

Our contact details:

Eldarvägen 6, 187 75 Täby

E-mail: aldcarmarket.se@aldautomotive.com

You can reach our data protection officer via:

data_protection.sweden@aldautomotive.com

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

PROCESSING	LEGAL BASE	DATA SUJECTS CONCERNED	DATA COLLECTED
Assessment and identification of the future customer and customer (KYC process)	Contract	Legal representative	Surname, first name, position; e-mail address; phone and mobile number, identification document, personal identity number, home address, Chamber of commerce proof, bank account details.
Management of the contractual relationship car dealers and traders	Contract	Legal representatives	Surname, first name, position; e-mail address; phone and mobile number, identification document, personal identity number, home address, Chamber of commerce proof, bank account details.
Anti-money laundering and fighting the financing of terrorism	Legal obligation	Legal representatives; Board members; UBO;	Surname, first name, position; e-mail address; phone and mobile number, identification document, personal identity number, home address, Chamber of commerce proof, result of screening against EU-sanctions lists.
Marketing or promotional activities; Sending newsletters, surveys, or satisfaction polls	Consent	Contact person	Surname, first name, e-mail address, telephone number,
Pick-Up Services	Legitimate interest	Person collecting vehicle according to PoA.	Surname, first name, personal identity number, phone number.

4. How long do we keep your personal information;

Personal data is kept by ALD Automotive, in an active base, for the time necessary to achieve the objective pursued at the time of their collection or as required to comply with ALD Automotive legal obligations.

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

purged; or
anonymized.

5. Who ALD Automotive 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 internally with ALD’s affiliates/ SG Group in order to streamline the know-your-customer 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 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, depending on the type of processing and legal base.	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

Please note that at any time you have the right to address a complaint to the competent supervisory authority, Integritetsskyddsmyndigheten.

8. Security and data storage;

ALD Automotive 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 Automotive makes 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 Automotive may collect data via so-called cookies in order to improve the use of our website ALD Carmarket.com. 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 September 8, 2022.

11. How to contact us;

To exercise the rights set out in the article 7, at any time, please send us a letter or an email to the following address ALD Automotive AB, address : Eldarvägen 6, 187 75 Täby or contact your local ALD Data Protection Officer through data_protection.sweden@aldautomotive.com , and we will handle your request.