Local data controller
ALD Automotive Eesti AS
Sõpruse pst 145, Tallinn, Estonia
Telephone number 372 630 8960
Competent local data authority: State Data Protection Inspectorate
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 endeavour 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.
How long do we keep your personal information?
We retain your personal information as long as you or your organization enjoy a business relationship with ALD Automotive and as long as limitation period expires, or the term applicable under local law since our last contact, or as required to comply with ALD Automotive’s legal obligations. If the term required to comply with ALD Automotive’s legal obligations are shorter when limitation period, we retain your personal information as long as limitation period expires and vice versa.
In case of litigation, we may keep your personal information until the end of such legal action, including any potential periods for appeal. We will then either delete or archive it according to the law in force.
In any event, your personal information will not be kept in a form that allows you to be identified for any longer than necessary by ALD Automotive for achieving the purposes for which it was collected or processed, or according to the relevant laws in force.
Example retention periods on the general level are described further. ALD Automotive is entitled to unilaterally change the retention periods at any time. Besides, retention periods stipulated by applicable law might be subject to change from time to time.
10 years retention period shall apply in respect of any personal information collected during contractual or precontractual relationship between you or your organization and ALD Automotive. Commencement of the retention period is next date after our contractual relationship ends or the next day after we contacted you, if only precontractual information has been gathered.
1 month retention period shall apply, however until the expiry of the limitation period of a claim for compensation for damage (if limitation period is longer) in respect of the candidate’s personal information gathered during recruitment process in respect of refused candidates, unless the candidate gives his/her consent to include his/her personal data into ALD Automotive candidates’ data base for future recruitment. The retention period starts the next day after recruitment process ends.
3 years retention period after the end of the contract shall apply for processing of your personal information for ALD Automotive Eesti AS own products and services direct marketing if you did not object to get direct marketing material.
12 months retention period shall apply in respect of your personal information gathered on your visit to ALD Automotive Eesti AS office.
How do we ensure the security and integrity of your personal information?
We protect your data through technical and organizational security measures (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
Only those teams and employees who need to know your information within our company can access it. We make 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.
How can you express your preferences on the use of your personal information?
To exercise the rights set out in the following section at any time, please contact ALD Automotive Eesti AS by e-mail: firstname.lastname@example.org and we will handle your request.
Withdrawal. In cases where you have given your previous consent for your information to be processed, you can withdraw that consent any moment.
Access. You can request access to your personal information we maintain about you. If you make such a request, we will provide you with all the information on the purposes of the processing, categories of data processed, categories of recipients, data retention term, your rights to rectify, delete or restrict the data accessed if applicable, etc.
Portability. You can also obtain a copy of any personal information that we hold about you in our records in a format compatible and structure to allow you to exercise your right to data portability.
Restriction. You can request a restriction in the following cases:
- for a period enabling ALD Automotive to verify the accuracy of your personal data in the event you contest the accuracy of your personal information;
- if the processing is unlawful and you wish to restrict your personal information rather than deleting it;
- if you wish ALD Automotive to keep your personal information because you need it for your defence in the context of legal claims;
- if you have objected to the processing but ALD Automotive needs to check whether it has legitimate grounds for such processing which may override your own rights.
Rectification / Erasure. You may also request that we correct, amend, erase, any information which is incomplete, out of date or inaccurate.
You can request the deletion of your personal information in the following cases:
- if your personal information is no longer necessary for the purpose of the data processing;
- if you have withdrawn your consent for data processing based exclusively on such consent;
- if you objected to the data processing;
- if the personal information must be erased to comply with a legal obligation applicable to ALD Automotive. We will take reasonable steps to inform other ALD Automotive entities which might be involved in the data processing of such erasure.
Objection. You can also object to the processing of your personal information at any time when used for marketing purposes or profiling to send you targeted advertising or to object to the sharing of your data with third parties or within the ALD Automotive Group.
Complaint. You also have the right to lodge a complaint with the competent supervisory authority. You can also provide your instructions regarding the storage, deletion or disclosure of your personal information after your death. Such instructions may be general or specific.
Specific conditions concerning your personal data
What activities and people are concerned by data collection?
This Policy applies to all sources of data collected and processed by ALD Automotive globally in the context of various Group activities such as corporate car leasing, private car lease, sales locations, fleet management services, third-party sources, recruitment process, use of our websites or mobile applications, and all offline processing activities.
We may collect and process your personal information if you are among the following categories: private client, drivers of leased cars or your organization cars, when ALD Automotive provides fleet management services, business-to-business customers’ contact, partners, dealers, geographical partners, prospects, fleet managers, shareholders, beneficial owners, ultimate beneficial owners, managers, candidates, etc.
Who controls the data?
In Estonia, ALD Automotive Eesti AS carries out the data processing activities described above. This section applies to the processing of your personal information by ALD Automotive Eesti AS as data controller.
How do we use your personal information?
ALD Automotive Eesti AS uses your personal information to offer you or your organization better services.
Therefore, ALD Automotive Eesti AS may use your personal information in the following cases:
(a) When necessary
(i) on a general level (ALD Automotive Affiliates), to manage the commercial relationship with you and your company, identify the persons authorized to maintain contacts, submit orders, conclude and terminate agreements, grant authorizations, respond to estimate requests, fulfill your or your company’s orders for services and for related activities, manage events, send you communications related to your or your company’s contract (for example notification of periodical inspections), respond to your or your company’s inquiries and requests for verifications, provide customer service, resolve your or your company’s complaints and/or claims, support and related training of our personnel involved in such activities, and to provide other services related to your or your company’s account;
(ii) identify the persons who enters ALD Automotive Eesti AS office;
(iii) for white-label partners: for fleet management services with reports and widgets, for key accounts, call center assistance and follow-up of international key account fleets;
(iv) for the purposes of international customer relationship management (ALD SA) in the context of car leasing activities by its subsidiaries, with clients being managed by ALD SA at a global level, to perform satisfaction and quality measurement, to consolidate quality information worldwide to create a global assessment of company quality, to provide management satisfaction surveys on products, services or contents, and to follow-up customer relation claims and after-sale service;
(v) to provide customer satisfaction surveys to professional traders about the remarketing of leased cars service (ALD Automotive Affiliates) via the online platform to market used cars coming from the leasing contracts).
(vi) to perform customer satisfaction surveys of the service quality and the customer satisfaction level regarding your ordered products and services;
(vii) to make statistics;
(viii) to maintain accounting, connected with settlement of tax liabilities and correctness of the accounting books;
(ix) to perform financial reporting to ALD executives (Sales, Procurement, Finance & Risk, Pricing, Insurance), including invoicing consolidation and profitability targets, operational performance of ALD group, procurement and litigation.
(x) to archive the documents assuring continuous and undisrupted business and protection against various claims and statements and complying with requirements of the law;
(xi) to provide drivers with car monitoring applications (e.g. Ecodrive) or provide managers with fleet management tools;
(xii) to report to clients on customer satisfaction survey results;
(xiii) to provide you direct marketing material of ALD Automotive Eesti AS own products and services if you are the customer of ALD Automotive Eesti AS and you did not object to get direct marketing material;
(xiv) to comply with Anti-Money Laundering and Counter-Terrorism Financing requirements, including Know Your Customer (KYC) requirements;
(xv) to maintain business records for legal, administrative and audit purposes;
(xvi) to meet legal, insurance and processing requirements;
(xvii) to take actions upon your request aimed at conclusion of an agreement with ALD Automotive Eesti AS, including customer screening, credit check and "Know Your Client", customer rating establishment.
(b) With your informed knowledge and consent
(i) Marketing purposes (except direct marketing as stated in part a) above): we may use your information to contact you, subject to your consent when applicable, about new offers or services and special offers we think you will find valuable, or to send you marketing communications or newsletters; we may analyse your client profile and preferences, and perform multichannel marketing campaigns via automated tools, contact you via SMS, email, or send you brochures;
(ii) Marketing purposes connected with products and services of ALD Automotive’s partners;
(iii) Customer satisfaction (except customer satisfaction surveys as stated in part a) above): based on targeted marketing tools and analysis, we may send you qualitative surveys for our products and services;
(iv) We may also invite you to participate in marketing events, games, or quizzes, through our mobile applications and/or websites.
(v) Websites, Cookies & Newsletters: we may collect information through cookies to provide us with an enhanced experience and improve your browsing experience notably to store your preferences and parameters to save you time, (such as languages preferences), enable log in, fight against fraud, and analyse the performance of our website and services.
This information helps us enhance our web sites and apps and better understand the products and services you would prefer.
While we may install functional cookies to facilitate your visit to our web sites or apps, you can express your preferences regarding cookies used for behavioral targeting advertising through the privacy settings options of your browser, which should include features to prevent information from being stored on the terminal or the processing of information already stored on such terminal, unless you turn on the feature to allow such storage or processing.
If you chose to block all cookies (including necessary ones), you can experience problems viewing all or some pages in our website.
(vi) Profiling: to improve our understanding of your interests and concerns: we may use your personal information to improve our website and services, to customize your experience with us and to tailor our marketing activities to fit your needs and interests. We believe that it is also in our interest to better serve you and respond to your needs, when required under regulatory obligations.
What type of personal information do we collect?
We collect the following types of personal information:
- Identification and Contact information, such as your personal code and/or date of birth, name, last name, personal telephone/mobile number, home address or email address, the date when you entered ALD Automotive Eesti AS office and an employee of ALD Automotive Eesti AS you visit;
- Recruitment related information, such as your CV, motivation letter;
Professional information, such as your job title, professional address and email, business telephone/mobile number, your professional experience, workplace;
- Role in the Company, such as your engagement in managing the company as CEO, representative of the company, member of the board or supervisory board, shareholder, beneficial owner, ultimate beneficial owner, number of shares you own in the company, decision making rights you enjoy;
- Financial/Credit information, such as your Credit Acceptance Date, contract information, your income and financial liabilities, your creditors, credit history, creditworthiness, creditworthiness reports, bank account numbers;
- Private details, such as your gender, date of birth, language(s), personal information, when you communicate with us through social network, visit our account on social network or see our entries or videos on social network, such as your e-mail, username, IP address, your personal preferences (using “Like”, “Follow, etc.), communication data, date;
- Contract related information, such as the vehicle (including model, plate number, etc.) you are driving or for which management you are responsible (also when the vehicle is leased / owned by your company), insurance related with the vehicle, accidents, fines, mileage of the vehicle, other data related with the vehicle (including vehicle last revision date and results, etc.), communication data, invoicing, etc.;
- Driver data, such as the number/copy of the driver's license, issue of driver’s license date and expiration date;
We may also collect information about you indirectly from our business partners, your organization or social media platforms.
We collect your personal information either directly from you (e.g., if you create an account on one of our sites or your organization opens account on our sites and you log in to it, or you make a purchase), or passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms, your organization, our business partners).
Cookies and other Tracking Tools
In order to provide you with a better experience, when you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons (e.g. Google Analytics).
If you use our web sites, we may collect information about the browser you are using, and your browsing behaviour.
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.
Cookies we use are of "analytical" nature. They allow us to recognise and count visitors, and to learn how our website is used. Thanks to this, we are able to improve the website – e.g. by making it easier to search for desired content. Additional information about specific cookie types and their purposes can be found in the table below.
This cookie is normally saved in the web browser upon the user's first visit to our website. Shall the
user delete it from the browser and then visit our website again, a new utma cookie with a new unique identifier will be saved. This cookie type is used for establish the number of unique visitors to our website and is updated every time the website is displayed. The cookie is also fitted with a unique identifier that is used by Google Analytics for ensuring its validity
and accessibility. The identifier is an additional protection.
|After 2 years from a visit to the website
This cookie is used for establishing
and continuing sessions for users visiting our
website. When the user views a page, the Google Analytics code attempts to update the cookie. If it fails to find it, a new cookie is created and a new session is established. Every time the user visits another page, the cookie is updated and programmed to expire after 30 minutes – this means that a single session lasts as long as the user's activity in 30-minute intervals. This cookie expires after the user has discontinued using a given page for longer than 30 minutes.
|After 30 minutes from a visit to the website
This cookie works in tandem with a utmb cookie. It is used for deciding whether a new session should be opened for a given user. This cookie has no expiry date – it expires after the user has closed his/her web browser. If the user visits a website, closes his/her browser and then comes back to the website within 30 minutes, then the lack of a utmc cookie shows that a new session should be started despite the fact that his/her utmb cookie has not expired yet
|End of session
This cookie type stores information about how the user has reached our website – he/she typed the address into the browser search window, used a link, found the address in the web browser or came across it in an ad or a link in an email. This cookie is used for calculating traffic generated by search engines, advertising campaigns and navigation within our website alone. It is updated each time when a page is viewed.
|After 6 months from a visit to the website
||These cookies adjust visited websites to the visitors' preferences by controlling the menu, animations and font size for better viewing. They modify the website's look and/or functioning. They are NOT USED for creating user-adapted ads
||End of session
This cookie helps to accurately establish the number of visitors and the extent to which the website is used.
| End of session
When you or your company uses car leasing or fleet management services with us, we shall collect information about the vehicle (such as the vehicle registration plate, or the vehicle last revision) and the driver's behaviour (such as accidents, fines, mileage of the vehicle), to provide the car leasing or fleet management services in accordance with the contract and invoice you or your company].
ALD Automotive Eesti AS created and administrates accounts on Facebook. Personal information, which you provide on Facebook (including notices “Like“ and “Follow“, other communication) or which is gathered when you visit our Facebook account or when you read our entries, watch our videos on these social networks are controlled by social network Facebook. Therefore, we encourage you to read carefully private notices of Facebook and to refer to them directly for your personal information processing.
ALD Automotive Eesti AS as administrator of Facebook account may choose settings, depending on its target audience, business management goals. Social network manager may limit possibilities for us to change some settings (for example essential account settings) and as a result of that we cannot affect your personal information to be gathered by the social network managers.
All such setting (chosen by us or set by social network managers) may impact use of your personal data when you approach social network. Even if your activity on social network is limited to just watching our entries or videos on social network, your personal information, such as the device you are using, or your IP address might be gathered by social network administrator.
Usually, the social network manager your personal information (including data which are gathered as a result of our account settings) processes for the purposes established by social network manager, following its privacy notices. However, when you use social network, communicate with us through it, visit our account on the social network or just watch our entries or videos we also get your personal information. The scope of personal information depends on settings of our account, our agreement with the social networks manager for additional services, cookies, used by social networks managers.
If you need more information about personal data processed on social network Facebook, please read Facebook private policy https://www.facebook.com/policy.php
and Facebook cookies policy https://www.facebook.com/policies/cookies/.
Who do we share your personal information with?
We understand that you do not want us to provide your personal information directly to third parties for their own marketing purposes without your consent. However, we occasionally need to use partners or processors to provide you with the requested services and a better experience, for the purposes described above. We therefore limit our sharing of your personal information on a need-to-know basis as follows:
- with internal business departments such as sales, customer care/quality department, marketing, IT services, support and maintenance. Inside the ALD Automotive Group, we may share your personal data with other ALD Automotive entities, who may only use your personal information in compliance with this Policy.
- with our service providers, such as data hosting service providers, data administrators, located in France or within the European Economic Area and instructed to only use your personal information in accordance with our instructions.
- with car dealers cooperating with us and companies managing vehicle receipt and delivery, workshops cooperating with us: mechanics, body and painting, glass, tyres workshops.
- with insurance companies and our insurance broker.
- with unaffiliated marketing partners, but only if you have given us your consent.
- with your organization for performance of the contract concluded by us and your organization.
- where needed to affect the sale or transfer of business assets, in connection with a bankruptcy proceeding, to enforce our rights, protect our property, or protect the rights, property or safety of others, debt recovery, or as needed support external auditing, compliance and corporate governance functions.
- when authorities and institutions as well as private bodies connect us with ticket or administrative proceedings concerning parking fees.
- when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.
Please note that we may also use and disclose personal information about you that is not personally identifiable i.e. personal information in an aggregate form that no longer identifies you.
How is your personal information transferred?
Some of the countries which receive or have access to your data may not provide the same level of data protection as the country in which you provided the information. You may obtain a list of these countries by contacting ALD Automotive Eesti AS by e-mail email@example.com.
Your information may be transferred to, stored and processed in any country or territory where one or more of our Affiliates are located outside of the European Economic Area for the purposes of managing customer relationship at the global level, providing unified car lease services with a globalized car fleet.
We may also transfer your personal information to the service providers involved in data hosting, maintenance and support services (located in countries such as India, the United States), or the provision of any other tool used for the processing of our customers or prospects personal information.
When we transfer your information, we protect and provide adequate protection for the transfer of your personal information to recipients in those countries by entering into data transfer agreements based on the European Commission standards clauses with such data recipients.
How can you contact us or the supervisory authority to lodge a complaint?
You can also lodge a complaint with the competent supervisory authority of the country where you are located if you have any concern about the conditions of processing of your personal information by ALD Automotive.
If you have a concern about the conditions of processing of your personal information by ALD Automotive Eesti AS and you wish to lodge a complaint to competent supervisory authority you should lodge a complaint to competent supervisory authority of Estonia.