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PRIVACY POLICY

At Accessit S.a.r.l. (hereinafter Luxauto) we respect and protect your privacy and believe that transparency is the key to good governance of personal data.

This Privacy policy explains what data we collect about you and how we use it, as well as the rights you have and how you can exercise them. We undertake to implement all appropriate means to preserve the confidentiality and integrity of your personal data.

I. Who are we?

Contact details Data Controller

Accessit S.à.r.l. (Luxauto), located in 5, rue Charles Darwin L-1433 Luxembourg, Grand Duchy of Luxembourg, carries out the processing of personal data, supplied by you or otherwise acquired during the performance of the services, as the controller of such processing.

Contact details Group Data Protection Officer

email: privacy@athome.eu

post: 5, rue Charles Darwin, L-1433 Luxembourg, Luxembourg

II. What personal data do we collect?

Only personal data strictly necessary for the achievement of the purposes mentioned below will be processed. In the context of our activities, and depending on the services you use, we may process the following data:

If you are acting as an “Individual” (private sellers-buyers), we will collect the following data:

Your identity information: last name, first name, identification data, etc.
Your contact information: e-mail address, phone number, etc.
Your economic information: bank data, etc.
Information regarding connection, geolocation and/ or browsing data (for example, the location data, the device identification, etc.).
Information about Your preferences in terms of car ad searches.
Information about your vehicle if you place an ad.
Commercial information (for example, if you want to receive communications or newsletter by email from the Group)

If you are acting as a “Professional Partner dealers” we will collect your identity and professional identification in the event that you contract any of our services as a Professional Client (legal entity), so we will process the following information relating to the natural person(s) representing you: name, surname(s), National ID Card/passport, telephone number, contact email address and, in some cases, documents proving your representation.

If you are acting as a "Candidate" we will collect:

Identification data (e.g., name, address), Contact data (e.g., phone number, e-mail address).
Personal details (e.g., date of birth, nationality, civil status).
Information regarding your Academic curriculum such certifications; professional experience, career, and current employment; publications; membership status (associations, charities) and Leisure activities and interests.
Other personal information such the criminal record extract will be collected/ checked for some specific job positions only if you are the selected candidate.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the website, Platform etc., we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please consider that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.

III. How do we use your personal data?

For what purposes and on what legal basis do we use your personal data?

Depending on the purpose for which we process your data from time to time, as explained below, we need to process one or other data, which will in general be, depending on each case, as follows:

We will first use your personal information to perform our contractual obligations to you or in order to take steps at the request of the data subject prior to entering into a contract , including to:

As an Individual, we will process your personal information:

To manage your registration, grant you access to its various functionalities, products, and services available such publish your ads or selling your vehicle to a garage.
To provide our services to our partners when you request any of the services, so that they can contact you and process your request in order to satisfy information relating to your vehicle searches.
To provide you with the customer support services.

As a Professional, we will process your personal information:

To create an account by registering via https://prov2.luxauto.lu/ and manage your professional access as a user of the website or application, grant you access to its various functionalities, products, and services available to you.
As a representative or contact person, we manage your personal data to perform, maintain and conclude the commercial relationship agreement. This purpose includes processing your data, mainly to contact you for invoicing, provide updates or informative notices related to the contracted functionalities, products, or services, including statistics, quality surveys and to be able to establish the degree of customer satisfaction with the provided services.
To provide you with the customer support service

As a candidate we will collect and process your personal information you have provided by sending an application, by responding to a job posting, by submitting your CV, etc. through the different recruitment portals for the purpose of selecting and recruiting new collaborators.

We may also use your personal data to comply with our legal obligations, in particular with regard to:

Our tax accounting obligations.
When your request is related to the exercise of your rights on which we inform you below, or to claim on our products or services, we are legally permitted to process your data for compliance with our legal obligations.
If you have contracted a paid service, are an Individual or a representative or contact person of a Professional, we will also process your data to handle any claims you may owe us for our services.

Based on our legitimate interest, we may process your information in order to:

To manage our customers and have a global view of customers (for example by compiling statistics of our customers, product surveys in order to know who they are and to know them better).
We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised
To ensure the security of the company's property and people, as well as networks and IT systems.
To establish, exercise, defend and preserve the rights of the company or the persons it may represent, for example in disputes.
To offer you personalized services or to show you customized information, whether on our website, platform or those of third parties, as well as to engage in data enrichment we consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such your preferences regarding the type and characteristics of vehicles in which you are interested and the personal data that you have provided us, such as the age range language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences)
Usability and quality analysis. - We consider that we have a legitimate interest in analyzing the usability and degree of user satisfaction as we understand that the processing of this data is also beneficial to you because the purpose is to improve the user and customer experience and to offer a higher quality service.
To invite you and participate as a Partner to events organized by the group.

Based on your consent, we may process your information in order to:

To create your alerts and receive the new listing to the email you have provided.
To provide you with and assist you in any services of interest to you that are offered by entities of the group such as atHome Home S.a.r.l, atHome Assurance S.a.r.l and Taxx S.a.r.l. In this case, if you have given your prior consent, we will share some of your personal information with the relevant group department or entity in order to provide you with these services.
To receive the group's newsletters if you have subscribed to them. Remember that you can unsubscribe from the newsletter at any time and free of charge using the information we provide in each communication.

We may not use your personal data for new purposes. In any event, prior to using personal data for other purposes, we will inform you about such change to this Privacy Notice and, in case of new processing activities based on the consent, we will offer you the chance to decline participation in these changes.

Do we use your personal data to make automated decisions?

We do not use your data to make automated decisions. If we decide in the future to do so, we will inform you in advance and explain the logic behind such decision-making and the significance and intended consequences of such processing.

IV. How do we share and transfer your personal data?

Who has access to your personal data and to whom is it transferred?

We may disclose your data to third parties in the following cases:

Companies belonging to the same group, and which are linked to the latter by an "Interprivacy Agreement”, which defines the roles and responsibilities of each of its different companies.
The Luxauto’s service providers who are responsible for the processing of your data, including those who provide us with technology services or services for sending, receiving documentation and support tools for measuring the operation of the Website and Apps, may have access to your data.
To our Partners Dealers and any other commercial partners when you request any of the services, so that they can contact you and process your request in order to satisfy information and contact requests relating to specific vehicle searches, the data will be communicated to partner garage agencies and/or private advertisers of reference.
Your data might be disclosed to third parties to comply with a legal requirement.
In the event of a dispute, your data may be transmitted to our lawyers and used to defend our case in court.

Data processed on behalf and Transfer of personal data to a Third Country

Luxauto uses companies belonging to the same group, and which are linked to the latter by an "Interprivacy Agreement”, which defines the roles and responsibilities of each of its different companies.
Luxauto also uses some IT providers for the management and maintenance of our information systems.

For service efficiency purposes, some of these providers can be located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate safeguards and always keeping your data safe, using the most convenient international data transfer tools, in example the Standard Contractual Clauses and any relevant supplementary measures. You may consult the content of such Standard Contractual Clauses through the following link: ec.europa.eu

V. How long will your personal data be kept?

For the registration as an Individual or as a Professional, we will process your data for the time during which you remain a registered user (meaning, until the relationship has finished).
For customer support services, we will process your data for the time necessary to meet your request or application.
In accordance with the provision governing the retention of personal data and with regard to the nature of the tax and accounting obligations, the retention period of your personal data is set at five (5) years or up to ten (10) years.
For Analysis of usability and quality, we will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.
Marketing purposes: We will process your data until you unsubscribe or cancel your subscription. Likewise, we will show you personalized ads until you change your device, browser and or cookies settings so that permission to do so is revoked.
In the context of recruitment process, Luxauto does not keep your personal data longer than necessary for managing recruitments applications. Your data will be deleted 12 months after the recruitment process has been finished unless you have given your consent to keep your cv for further opportunities. However, if you finally are hired, your data will remain as part of the employment file. We will not keep any criminal record except in case of specific job positions typified by law.
We will also keep your data for as long as necessary for the achievement of the purposes such a legal obligation imposes such retention.

VI. What are your rights and how can you exercise them?

As a data subject, you have different rights. Below is a brief description of these rights and how you can implement them.

Right to information – You can direct any questions about the storage and processing of your data to us.

Right of access – You may, at any time, obtain confirmation as to whether or not personal data concerning you are being processed and, where applicable, access to such data and a free copy thereof.

Right to rectification – You may, at any time, by sending us a written request, obtain the rectification of personal data concerning you that is inaccurate. You can, in the same way, request that incomplete data be completed

Right to erasure – You may, at any time, by sending us a written request, obtain the erasure of your personal data.

Right to restriction of processing – Where restriction of processing is granted, personal data may only be processed with the consent of the data subject, or for the establishment, exercise or defense of legal claims, or for the protection of the rights of another natural or legal person, or for important reasons of public interest.

Right to object – You have the right to object, at any time and by sending us a written request, on grounds relating to your particular situation, to the processing of your personal data based on the legitimate interests we pursue. We will no longer process this personal data unless it is demonstrated that there are compelling legitimate grounds for the processing that override your interests and rights and freedoms, or for the establishment, exercise, or defense of legal claims. When your personal data is processed for direct marketing purposes, you have the right to object to this processing at any time.

Right to portability – You have the right, by sending us a written request, to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.

Right to withdraw consent – Where processing is based on your consent, you have the right to withdraw consent at any time by sending us a written request. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent made before the withdrawal of it.

Right to lodge a complaint – We make our best efforts to ensure compliance with our legal data protection obligations and to respond as quickly as possible to any complaint addressed to us in this regard. In the event that you are not satisfied with the response received, you have the possibility to lodge a complaint with the Data Protection Authority.

National Commission for Data Protection
15, boulevard du Jazz
L-4730 Esch-sur-Alzette

Phone : (+352) 26 10 60 -1
https://cnpd.public.lu/fr/support/contact.html

VII. Data Security

Luxauto undertakes to ensure the protection and security of Personal Data, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties or used in an unlawful manner.

Luxauto maintains adequate physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction. As part of those safeguards, Luxauto employs sophisticated technology designed to protect Personal Data during its processing and prevent processing errors or unauthorized acts of third parties.

VIII. Information on cookies

We use cookies to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits.

Please read our Cookies Policy to understand with greater detail the cookies that we use, their purpose, how to manage your preferences, as well as other information of interest.

Google Analytics

For the purposes explained above, our platform uses the web analysis service Google Analytics, which is offered for users from Europe, the Middle East and Africa (EMEA) by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies and similar technologies to analyze our website based on your user behavior. Google will process the information obtained in order to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage. The data arising in this context can be transmitted by Google to a server in the USA for evaluation and stored there. The IP address is shortened before the evaluation (IP anonymization) so that no conclusions can be drawn about your identity.

The following data are processed by Google Analytics:

Anonymized IP address.
Referrer URL (previously visited page).
Pages accessed (date, time, URL, title, length of stay).
Downloaded files.
Links to other websites clicked.
If necessary, achievement of certain goals (conversions).
Technical information: operating system; Browser type, version, and language; Device type, brand, model, and resolution.
Approximate location (country and possibly city, based on anonymous IP address)

Google Ads Conversion Tracking and Ads Remarketing (formerly AdWords)

Our platform uses the "Google Ads" service, which is provided for users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads, customer actions defined by us (such as clicking on an ad, page views, downloads) are recorded and analyzed using “Google Ads conversion tracking”. We use “Google Ads Remarketing” to show you individualized advertising messages for our products on partner websites from Google. We also use the functions of "GA Audience" in this context. Both services use cookies and similar technologies for this.

The data arising in this context can be transmitted by Google to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Google.

If you have not consented to the use of Google Ads, Google will only display general advertising that was not selected based on the information collected about you on this website. In addition to revoking your consent, you also have the option of deactivating personalized advertising in the advertising settings on Google.

Non-personalized ads from Google Ads Manager

We also use Google Ads Manager for Non-personalized ads which are not based on a user’s past behavior. The users are targeted using contextual information, including coarse (such as city-level, but not ZIP/postal code) geo-targeting based on current location, and content on the current site or app or current query terms.

Google disallows all interest-based audience targeting, including demographic targeting and user list targeting. Although non-personalized ads don’t use cookies or mobile ad identifiers for ad targeting, they do still use cookies or mobile ad identifiers for aggregated ad reporting and to combat fraud and abuse.

Please read our Cookies Policy to understand with greater detail the cookies that we use, their purpose, how to manage your preferences, as well as other information of interest.

IX. Additional information on certain functionalities of the Website and Apps

User registration and password

When you register on the Web and Apps you will define a username and password that will allow you to log in, at any time, as a "Registered User" and, therefore, manage your relationship with Luxauto. The password can be changed. It is essential that you keep your password confidential at all times and do not make it available to third parties. It would be advisable not to use the same password for all your personal accounts so that, in the event of any third party accessing them without your consent or unlawfully, they cannot access the different accounts you have on different sites.

Luxauto/tools

You have the possibility to use the login or sign in through a social network or another collaborator that enables this service (social login) when it is available on our login/sign in screen, either to link the social login to your account or by registering a new one.

In that case, your login credentials, your name, and email / phone number (you might need to authorize it), will be imported from your social network or collaborator account.

The use of this functionality may imply that you provide certain information about your activity to the social network or the collaborator. In any case, we recommend that you review your privacy settings and the privacy policies of the collaborator or social network to learn how these third parties process your data.

What happens when you integrate your Facebook account with the Luxauto/tools software?

When you integrate your Facebook account with our Luxauto tools software, we export relevant information to give you a better experience of our service.

What data do we receive when you integrate with your Facebook account?

Facebook account: we will receive your Facebook profile account such your name, surname, email address, telephone number, any picture, as well as the communications that are encrypted in our databases.

Who will have access to your data once you integrate with your Facebook account?

You, having integrated your Facebook account, and us, Luxauto as users at administrator level, as supervisors. We will only import the information that is relevant for the integration with Luxauto/tools

X. Changes of the privacy notice

We may amend the information contained in this Privacy Policy when we consider this appropriate.

We suggest you review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.