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Privacy Policy

1. GENERAL PROVISIONS

1.1. It is provided in this privacy policy, which personal data we collect and for what purposes we process them when you visit website www.alfaromeo.ee and use the services contained therein (hereinafter - the Policy). 1.2. The Policy is applied when the Company receives the personal data because the data subject uses the website and the possibilities it provides. It is designed to protect and defend the data subject's data against unauthorised use. 1.3. The capitalized terms in this Privacy Policy have the meanings given below, unless the context requires otherwise: 1.3.1.  “Personal data” means any information concerning an identified or known natural person or the person, whose identity can be identified, directly or indirectly, using relevant data (e.g., name, surname, e-mail address, vehicle state number, etc.); 1.3.2.  Company – UAB “Autobrava”, legal entity code: 125481247, registered office address:  Žalgirio st. 112A, Vilnius, LT-09300, Lithuania,  the data of the Company are collected and stored in the register of legal entities, acting as the processor of data controllers, which  transfers the personal data collected through the website  alfaromeo.ee to the data controllers. 1.3.3. Website means the Company's web page, which is accessible via the online address www.alfaromeo.ee; 1.3.4. Data subject means a natural person from whom the Company receives and processes the personal data through the website; 1.3.5. Data controller – Andmevaldaja on Aktsiaselts United Motors , registrikood 10527085 , juriidiline aadress Reti tee 4 Peetri alevik, Rae vald Harju maakond, 75312. 1.3.6. Account - a link to the Website on the relevant web page; 1.3.7. A cookie is a small file that a browser takes from a website that is used by a data subject and saves it to a device. Cookies allow the website to remember information about browsing habits, actions, searches, and settings in order to use the full functionality of the site, while other visits to the site are simpler and more useful. 1.4. During processing of your personal data, we comply with the legal acts governing the processing and protection of the personal data including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).

2. BASIC PRINCIPLES FOR PROCESSING PERSONAL DATA

2.1. The information we collect about you depends on the information you provide to us when you register for the purchase of products and/or services offered on the site, agree to the use of cookies and/or subscribe to newsletters.   2.2. During using the website, you are not obliged to provide us with any personal data, but it is possible that in such a case we will not be able to provide you with the opportunity to purchase services and/or products offered on the site. 2.3. The data provided during your use of the website is collected and then processed by the data controllers specified in Item 1.3.5. of this Policy. 2.4. We collect personal data that you provide when you use the website and register in order to acquire the products and/or services offered by the data controllers, namely: 2.4.1. Basic information – name, surname, city, e-mail address and telephone number; 2.4.2. The data related to registration on the site for purchase of services and / or products offered on the site - the ordered product, car model, car licence plate, information about consent and disagreement regarding the processing of the personal data for direct marketing purposes (registering for the newsletter) and related records; 2.4.3. Other data about the use of the site - data collected through the use of cookies and similar technologies related to internet browsing, etc. 2.5. Personal data of the data subject shall be used for the following purposes: 2.5.1. Provision and administration of the services provided on the website; 2.5.2. The submission and examination of requests from the website; 2.5.3. Improving the quality of the customer service and information by recording telephone conversations; 2.5.4. Increasing representation and awareness in public spaces, while communicating in social networks; 2.5.5. Implementation of direct marketing with the data subject's consent. 2.6. In all cases mentioned above, the data controllers process your personal data only to the extent necessary for the achievement of clearly defined and legitimate purposes, taking into account the privacy protection of the data subject. 2.7. Controllers ensure that the processing of the personal data would be accurate, fair and lawful, that they would be processed only for purposes, which meet the purposes set out before the personal data are collected, so that the processing of the personal data would be performed strictly in accordance with the statutory clear and transparent data processing requirements. 2.8. Controllers will store the information, provided in Items 2.4.1. and 2.4.2 of this Policy (except of your consent to the processing of Personal Data for direct marketing purposes) during the time of your registration on the site, not more than 3 (three) months when you submit your personal data when registering for a test drive and not more than 6 (six) months when you submit your personal data when registering for the Service, from the moment you submit your data to the site. 2.9. The data specified in Item 2.4.3. of this Policy are stored no longer than the term specified in the Cookie Policy mentioned in Item 4.1. of this Privacy Policy 2.10. Personal data, which are processed for the purpose stated in Item 2.5.2 of the Policy, are stored during the inquiry and for 3 months after its examination. Personal data can be stored longer if, within that time, a complaint or request, notice, claim, answer or other inquiry is not examined or the examination will continue, also, if the personal data are required to protect the legitimate interests of the Company or third parties, for example, in the case of the limitation period or legal dispute. If the complaint has been resolved  signing the peace agreement, personal data are stored for 10 years. 2.11. Please also note that records of telephone conversations with customer service personnel are made in order to ensure the quality of the services provided to you and to inform the data subjects. Before the interview is recorded, the data subject shall be informed of the interview recording and purpose.  Recordings of telephone conversations shall be kept for 6 months and it is possible to listen to the recordings again in the event of or in case of suspicions regarding violation of this Policy, the provisions of the contracts for the sale and / or service of the Controllers and the Controllers‘ clients or the Controllers' internal rules, quality of services provided by data controllers, in cases of accidents or conflicts (incidents) with clients or employees, in cases of loss, damage or destruction of property. 2.12. Your personal data are stored no longer than it is provided for in this Policy, unless the law provides for a longer retention period for such personal details. 2.13. Your personal data are handled responsibly and securely. The company and the data controllers, both in determining the means of processing of the personal data and at the time of processing , shall implement the appropriate data protection technical and organisational measures, as set out in the legislation, to protect the processed personal data against accidental or unlawful destruction, damage, alteration, loss, disclosure and any other unlawful processing.  The appropriate measures shall be established taking into account the risks arising from the processing of personal data. 2.14. We note that at the time that was reserved during registration at the website, when you arrive at the place of sale of the data controller products and / or services and conclude contracts for the purchase-sale of products and / or services, your personal data will be processed in accordance with the provisions of the concluded contracts.

3. DIRECT MARKETING (NEWSLETTER) TERMS

3.1. If you have agreed to subscribe to the newsletter, your e-mail address and phone number can be used for sending of the personalized information about goods, services, discounts, offers, contests, events, news, surveys and other news by e-mail, mail, phone, SMS and for contacting you for these purposes.  The aggregated information will only be used to send the newsletter. 3.2. With joint marketing proposals, you may be sent general information, controllers will share this information with all their clients. 3.3. By providing personalized marketing offerings, you may be assigned to the appropriate client category of data controllers according indications of your interests (in the data controllers showrooms, by e-mail, phone, browsing controller‘s websites, or otherwise) in specific services and / or products of the controllers and their acquisition history, the data of participation in surveys, competitions and events organized by data controllers and the other similar indications. In these cases, the general information will only be sent to the relevant controllers‘ clients category. 3.4. When processing your personal data, we do not use automated decision-making processes, including profiling, which may result in legal consequences for you or which may have a similar significant effect. However, when we process your personal data for direct marketing purposes, we may assign you to the relevant customer category, so you have the right to require human intervention to express your views or oppose such attribution. 3.5. Controllers, in the legitimate interest of informing their customers of the availability of similar goods and / or services, may also contact you without the consent specified in 3.1. of this Policy, if the data controllers' goods or services (or similar goods / services) are offered or an opinion is sought on goods / services. In the latter case, the data controllers provide you with an easily enforceable opportunity to oppose the receipt of relevant communications. 3.6. Our newsletter is sent from the data controllers. We may transfer your e-mail address to third parties that provide specialized services for the purpose of sending you a newsletter. 3.7. The term of processing of the data (e-mail address and phone number) on the basis of Items 3.1. and 3.2. of this Policy: 5 years, but not more than the validity of your consent. 3.8. You can refuse sending of direct marketing messages sent on the basis of Items 3.1. and 3.2. of this Policy by clicking on the link at the bottom of the e-mail.

4. COOKIES

4.1. Cookie usage and data collection through cookies are governed by the cookie policy, which can be read using the active link. 4.2. The data subject is informed and expresses the prior voluntary consent or disagreement with the use of cookies on the website and the possibility of disabling them.

5. ACCOUNTS

5.1. Company‘s accounts are links to certain Web pages, which may contain the same information as the website, as the Company is the manager of both the site and the accounts. Account users are subject to the Privacy Policy of the website containing the Company Account and the rules of that page. 5.2. The site contains links specified below to other websites. For information about how your personal data are processed on these websites, we suggest you to familiarize yourself with the privacy policies published on these websites: 5.2.1. Facebook: @Alfaromeoeesti, the Privacy Policy of which is available at the address https://www.facebook.com/privacy/explanation 5.2.2. youtube: @wearealfisti, the Privacy Policy of which is available at the address https://policies.google.com/privacy 5.2.3. instagram: @alfaromeoeesti, the Privacy Policy of which is available at the address https://help.instagram.com/402411646841720

6. RIGHTS OF THE DATA SUBJECT

6.1. As a data subject, you have the following rights: 6.1.1. to request access to your personal data and obtain a copy thereof; 6.1.2. To request the correction of inaccurate or incomplete personal data or the suspension of any action taken using them; 6.1.3. To request the deletion or restriction of surplus or unlawfully processed personal data; 6.1.4. To ask to transfer your personal data to you or to any other controller where technically possible using a systematic, common and computer readable format; 6.1.5. the right to withdraw the consent at any time where the processing is based on the data subject's consent according to p.1 (a) of Article 6) without prejudice to legality of consent-based processing of data prior to withdrawal of consent; 6.1.6. object to the processing of your personal data; 6.1.7. to submit a complaint to the state Andmekaitse Inspektsioonile (https://www.aki.ee/et). 6.2. As a data subject, you can enforce your rights by submitting a written request in person or via a representative to the controllers on their website. 6.3. By submitting a request, you as a data subject must verify your identity by one of the following methods: 6.3.1 if you submit the application to an employee of the data controller, you must provide a valid identity document at the same time; 6.3.2. if you are applying by mail or courier, you must enclose a copy of your valid identity document, approved in accordance with the procedure established by legal acts; 6.3.3. If you submit your application electronically, you must confirm it by electronic means that allow the person to be properly identified (e.g., mobile signature, qualified electronic signature, etc.).

7. FINAL PROVISIONS

7.1. For any questions relating to the protection of your personal data, you may contact the Controllers by contacting them on the Site. 7.2. This Policy shall be reviewed and updated at least once a year or whenever there is a change in the law governing the processing of personal data. 7.3. Controllers have the right to amend, in whole or in part, the rules described in this Policy. The data subjects will be informed about the changes when the Policy is updated on the Site. For this reason, we recommend that you would periodically visit our website, you will always find the latest version of the Policy there.

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