CONCERNING PERSONAL DATA PROTECTION
B. PERSONAL DATA COLLECTED
Our Company, acting in the capacity of Data Controller, collects and retains data you freely provide us with, as well as data obtained from third parties and which are absolutely necessary for our transactions. We may collect personal data from you when we sell to you any vehicle or accessories or spare parts or other products traded by our Company; when we provide you with after-sales services, such as vehicle repair/maintenance; upon custom clearance of your vehicles; when you test the vehicles of our Company (test-rides, test-drives); when you send us your resume in respect of a job vacancy; when you cooperate with the Company in the context of its commercial activities; when you participate as shareholders or shareholders’ proxies in the General Meetings of the Company; when you use our website or other websites accessible through our website; when you register for our electronic services; when you create an account in our website and/or our mobile apps; when you request information concerning the promotional activities of our Company (Newsletter); when you become a member of or comment in the Company’s social media accounts (e.g. Facebook, Instagram, Twitter, YouTube); when you participate in surveys or contests organized by our Company; and when you submit requests, complaints, comments, reviews or when you contact us.
In particular, we may collect the following categories of data:
– Personal information, such as full name, date of birth, civil status, driving license information, police identity card number, taxpayer’s identification number, your picture (photo), or other identification details that, as the case may be, are required in order to prove your age or identity, in accordance with the law;
– Contact details, such as home address or product shipping and delivery address, home telephone number, work address, work telephone number, mobile telephone number, fax, e-mail;
– License plane and VIN;
– Credit or debit card information;
– Education details, such as studies, skills, foreign language knowledge, professional experience (only when you submit an application for a job vacancy at the Company);
In some cases we may possibly request additional information or details with respect to a particular transaction that needs to be concluded. For example, it is possible that we may request from you tax information or forms, upon purchase of any vehicle traded by the Company subject to retention of ownership or in other cases, where a leasing agreement is concluded, etc., diplomatic identity details, certificates of studies or military service of your dependents, provided that our Company is involved in such relevant procedures. Finally, we may request from you sensitive personal data, where required by tax and/or customs legislation. In such cases, you will receive detailed information and grant your consent prior to the processing of such data.
In addition to the foregoing, when you purchase from our associates products traded by our Company, namely from our subsidiary company MOTODIKTYO S.A. and/or from our network of distributors in Greece, these associates of ours transfer to our Company your personal data [name, surname or trade name, gender, home address or business registered address, destination/purpose of use (private, professional, or for rent), taxpayer’s identification number, contact telephone number], which the Company may process in the capacity of Data Processor, exclusively for the purpose of providing warranty services for your new products.
C. LEGAL BASIS FOR PROCESSING
The legal basis for processing your personal data is, as the case may be:
a) The fulfilment of contractual and pre-contractual obligations. It is necessary that you provide us with any personal data that are required for the preparation and performance of the commercial relationship between us. Without such data, we are not able to process your respective requests and/or perform the contract between us.
b) Compliance with legal obligations of our Company or reasons of public interest. If the required data are not provided, we will possibly not be able to process your request or comply with our obligations under the law.
c) In order to secure the legitimate interests of the Company or third parties. In such cases, where you have to provide us with your data for such purposes, we will provide you with explicit notice. If we are not provided with said data, we will possibly not be able to process your request or respond to your wishes.
d) Your consent. If you have granted your consent for specific purposes, the purposes shall be evident from the respective content of such consent. In such cases, where you have to provide us with your data for such purposes, we will provide you with explicit notice. If we are not provided with said data, we will not be able to comply with your wishes, as such are indicated in your consent. You may withdraw your consent at any time without affecting the lawfulness of processing based on such consent before its withdrawal.
e) Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
We comply with the legislation and do not permit children to register in our websites and apps if younger than 16. We will request the parents’ consent with regard to children participating in our experiences and events.
D. PURPOSES OF PROCESSING
We shall process your personal data for the following purposes:
1. Performance of Company transactions
a) In order to contact you with regard to any matter that may arise in the context of any transaction between us, such as for the preparation/processing/submission of quotes, the performance of any contracts concluded, the execution/delivery of your order at your premises, the verification of your data and your identification, where necessary, the receipt of any prizes upon any contest draw, the response to any requests/questions you make;
b) In order to collect the price for our products or services and to issue the documentation required by the law;
c) In order to defend the legal rights of the Company before any judicial or other Authorities;
d) In order to meet our Company’s compliance obligations before any domestic or foreign supervisory authority;
e) In order to ensure the correctness and accuracy of the data, so as to allow for the proper performance of any transaction;
f) In order to contact you in case of any existing risk concerning any vehicle or other merchandise imported by our Company.
2. Drafting and preparation of internal studies and reports
We process your data in the context of market surveys and the preparation of studies and general reports that assist us in improving our services and products, receiving information concerning your experience and understanding your needs and preferences. Such processing further allows the Company to ensure the security and protection of transactions and compliance with the legislation applicable at any given time.
3. Warranties – Insurance
We process your personal data in the context of provision of warranties and insurance coverage, provided that such processing is necessary for the protection of our legitimate interests and where required in order to perform the contract between us. More specifically, in the context of providing the warranty, we may transfer personal data concerning you necessary for the provision of the warranty [name, surname, name, surname, gender, address, purpose of use (private, professional, or for rent), taxpayer’s identification number, contact telephone number] to the manufacturing firms of the products traded by us, exclusively for the purposes of providing the warranty.
4. Promotion – Advertising – Customer profiling
We contact you via electronic means in order to provide you with information concerning offers and products of our company, following a prior transaction between us. However, you have the right to choose whether to receive such communications or not. If you have granted your consent, the Company may process your data for the following additional purposes:
a) for the promotion of products and services;
b) for conducting qualitative surveys and/or analyses;
c) for participation in promotional activities.
E. DATA RECIPIENTS
1. The recipients of your personal data, to whom they are disclosed, are:
a) Company employees, related and cooperating companies, such as the manufacturers of products traded by us, for purposes of warranties or in cases of defects in such products, companies that provide services in the sectors of telecommunications, technical support, advertising, printing services, etc.;
b) external associates of the Company, such as custom clearance agents, legal, insurance and other consultants, to whom the Company assigns the performance of specific actions;
c) partners and service providers, in general, to whom the data are transferred for the processing of requests and/or performance of contracts with you or for ensuring legitimate interests, such as credit institutions, providers of transport or similar services;
d) public bodies or judicial authorities, such as public prosecutors, courts or tax and customs authorities, to which we are obliged to transfer personal data on the basis of mandatory legal provisions, in the context of their competencies, subject, in any event, to the obligation to respect the confidentiality thereof.
Beyond the aforementioned parties, your personal data shall not be further disclosed to any third parties.
2. Where data are transferred to our third-party associates, the Company shall ensure that its data processors meet the conditions and provide sufficient guarantees for the implementation of appropriate technical and organizational measures in order for the processing to ensure the protection of your rights.
3. Authorized third-party associates of the Company (e.g. Company distributors), as well as the manufacturers of the merchandise traded by us, may have access, depending on the circumstances, to your personal data. Your personal data are disclosed to the aforementioned persons, provided that such disclosure is necessary for the proper performance of the transaction and in order to ensure the high quality of the services provided by our associates.
4. In addition, we may transfer personal data to suppliers or service providers that are established outside of the European Economic Area (EEA). In such case, the personal data shall remain subject to a sufficient level of protection and to appropriate safeguards provided for in the legislation.
F. RETENTION PERIOD
We shall retain your personal data only for as long as necessary for achieving the purposes indicated herein or in the contractual documents, in general, that govern our relationship or – provided you have granted your consent – for as long as you have not withdrawn your consent. Further, we shall retain your data within the framework of our commercial and tax data retention obligations. In any event, such period shall not exceed twenty (20) years. Upon expiry of the aforementioned period, your personal data shall be destroyed. In particular, we delete your personal data as soon as the legal basis for processing ceases to apply, when they are no longer necessary for the purposes of preparing and performing a contract, provided that no other legal grounds exist, when you object, unless further processing is permitted in accordance with relevant provisions, if we are obliged to do so on any other legal grounds and, in any event, after twenty (20) years. By way of exception, we may retain some of your personal data for a period of twenty-five (25) years, for safety purposes and in case of any recall of products traded by our Company which you have purchased. It must be specifically noted that any resumes submitted in respect of any job vacancy at the Company shall be retained by the Company for a period of six (6) months as from submission thereof, upon expiry of which they shall be erased.
Where personal data retention is necessary for the exercise or protection of the Company’s legal rights before judicial or other authorities provided for in the applicable legislation, the above period shall be extended until such data are no longer necessary for the aforementioned purposes.
We make over time every effort to minimize the personal data we use, as well as to render them anonymous, in order to prevent any correlation with your person or your identification. In such case, we may use them without further notice.
G. CONTACT WITH THE COMPANY AND EXERCISE OF RIGHTS
In accordance with the legislation on the protection with regard to the processing of personal data, you have the right:
1. To request access to your personal data and, in particular, you may obtain information on which personal data concerning you are being or have been processed in the past, the purposes of such processing, the categories of recipients to which they are transferred, the scheduled retention period and their sources.
2. To raise any objections and to object to the processing of data concerning you, to request the erasure thereof, as well as to transfer your personal data to a different data controller, without any objection from the Company, or to request that the Company directly transfer them to a different data controller.
3. To request the rectification of personal data stored by us concerning you. This permits you to rectify any incomplete or inaccurate information concerning you that we may have.
4. To request the restriction of the processing of your personal data, only for specific purposes, provided that the correctness of the data or the legitimacy of the processing is contested.
5. To withdraw at any time the consent you have granted for the processing of your personal data, where processing in based on your consent. In such case, we shall cease the processing, without affecting the lawfulness of processing based on your consent prior to the withdrawal thereof.
6. To submit a report/complaint to the Competent Supervisory Authority [Hellenic Data Protection Authority, 1-3 Kifisias Ave., PC 115 23, Athens, tel.: 210 6475600, fax: 210 6475628, e-mail addresses: firstname.lastname@example.org, email@example.com].
In order to exercise your rights as above, you can address the Data Protection Officer of our company in writing, at the postal address of the Company (Aspropyrgos, Kyrillos Location, PC 19300) or at the e-mail address: firstname.lastname@example.org, and we will make sure to review your request and respond as soon as possible.
The Company may refuse to satisfy any erasure request where the retention of your data is necessary for the establishment, exercise or defence of its legal rights or those of third parties.
For any contact between us or for any questions concerning the processing of your personal data, you can contact us either by post at the address: MOTODYNAMICS S.A., Aspropyrgos, Kyrillos location, PC 19300 or at the e-mail address: email@example.com, or by telephone at 210 6293-500 or via fax: 210 6293-521.
H. COMPANY OBLIGATIONS
The Company is obliged to take every reasonable measure for ensuring the confidentiality and the security of data processing and their protection from accidental or unlawful destruction, accidental loss, alteration, unauthorized dissemination or access by any party and any other kind of unlawful processing.