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COTW Privacy Policy

Effective May 25, 2018

1. Overview

CarsOnTheWeb (COTW) cares about your privacy.

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our sites and services. Our aim is to protect and process your personal data with equal care in a manner lawful and transparent. (You; as a customer, possible future customer, website visitor or other natural person in contact with us. Us; as COTW group including Ecadis NV, CarsOnTheWeb Belgium NV, CarsOnTheWeb France SAS, CarsOnTheWeb Deutschland GmbH, CarsOnTheWeb Italia S.R.L. con Socio Unico, CarsOnTheWeb Nederland B.V. and CarsOnTheWeb Espana S.L.). Contact details can be found below and the end of this Policy.

 

2. Definitions

Personal data: Any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data may directly or indirectly identify you.

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. CarsOnTheWeb is the controller as regards personal data.

Processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

 

3. What Personal Data We Collect and Process?

The types of personal data we typically collect and process include

Identification Data: To register as a COTW customer, we collect your company name, address, phone number, email address and VAT number. If you wish to buy a product or service you must provide a copy of your ID and proof of trade certification.

Transactional Data: If you wish to buy a product or service, we collect additional financial information such as your bank account number.

Visiting Information: We trace certain information on the basis of your visit of our site and store certain types of information whenever you interact with us when using our channels: our internet websites, our apps for smartphone, etc. For example, we use "cookies" and we obtain certain types of information when your web browser accesses carsontheweb.com.

We do not collect nor use sensitive personal data relating to religious, political or philosophical beliefs, sexual orientation, ethnicity or health.

 

4. Why We Use Your Personal Data?

In principle, we will use your personal data

• As part of performing a contract,
• To comply with legal and regulatory provisions,
• For the legitimate interests of our company to be able to function as a commercial business,
• To provide you with relevant products and services when we have obtained your consent,
• Optimisation of the performance of our services,
• Prevention and detection of legal or regulatory breaches against laws and regulations we are bound by.

 

5. How Long We Keep Your Personal Data?

We do not keep your personal data any longer than is necessary for the purposes for which it was collected.

Regarding the prospect customers, we keep the personal data for 2 years. Customer and supplier data is kept during the term of the contract, and for the period legally required thereafter, as explained in the next paragraph.

When assessing how long to keep personal data, we respect the retention requirements stipulated by the applicable laws (for example 7 years for invoices).

In certain instances we may be obliged by a competent authority or due to an ongoing litigation to keep certain data longer than described above. In this case we will only keep the data as long as strictly required for the authority respectively for the litigation.

 

6. With Whom Do We Share Your Personal Data?

We share your personal data within COTW group and, in limited instances described below, outside COTW group.

We may transfer personal data to other COTW affiliates which are CarsOnTheWeb Belgium NV, CarsOnTheWeb France SAS, CarsOnTheWeb Deutschland GmbH, CarsOnTheWeb Italia S.R.L. con Socio Unico, CarsOnTheWeb Nederland B.V. and CarsOnTheWeb Espana S.L.

In some cases we are obliged by law to share your data with external parties,  to whom we are legally obliged to transfer personal data. These authorities are, but not limited to, tax authorities, the police, courts, arbitration/mediation bodies as well as lawyers.

We may also transfer personal data to trusted third parties. These third parties include internet service providers, cloud services, transport companies or financial institutions. We do not transfer your personal data to third parties for secondary use or unrelated purposes.

For third parties outside Belgium, we ensure that personal data is adequately protected in the foreign country. Where personal data is transferred outside the European Economic Area (EEA), personal data protection is different as in the EEA. In such cases, we have taken appropriate safeguards to ensure that personal data is processed using the same standards as apply in Belgium. These safeguards include EU Model clauses, password protection, encryption of data where appropriate, limited access to personal data as also further explained in the next paragraph.

 

7. Your Security Matters

As COTW, we are committed to taking all reasonable and appropriate measures to safeguard the personal data that we hold from loss, misuse or unauthorised access.

For this purpose, we have a security governance framework and authorize access to personal information only for those employees who require it to fulfil their job responsibilities.

 

8. Your Rights About Your Personal Data

You have the right to access your personal data. If you ask us, we will provide you a description of the personal data held by us, the reason we collect your data, the external parties to whom the data is transferred and the reasons for any automated processing of your data.

You have right to rectify your personal data. If you think that your data are inaccurate (or incomplete), you can ask us to rectify them.

You have right to erase your personal data. If you suspect that we are unlawfully processing your data, you can ask for it to be deleted.

You have right to restrict or to object to the use of your personal data.

You have right to move your personal data in scope of data portability.

 

9. Contact

Please contact us via following channels to send us any question on your personal data and privacy, to exercise your above rights and/or to stop receiving our personalized offers.

Email: privacy@carsontheweb.com

Tel: +32 (0)16 38 80 10

Postal Address: ECADIS NV, Grijpenlaan 19A, 3300 Tienen, Belgium, Attn: Data Protection Officer

If you are not satisfied with the way your request or complaint has been handled, you may report this to the Belgian Commission for the Protection of Privacy via the link below:

https://www.privacycommission.be/

We are committed to protecting your privacy. Please do not hesitate to contact us if you have further questions.

V.2.0 - 14/05/2018

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