Purpose

Your privacy is important to us. This Data Privacy Policy aims to explain how we collect, store, use and disclose your personal information whenever you use our products and services, our websites or interact with ALD Automotive EOOD or any ALD Automotive Group affiliates worldwide.
This Data Privacy Policy also aims to spell out the conditions that govern how we process and protect that information.

Data Controller

The data controller is ALD Automotive EOOD, a company registered in the Trade Registry with the Registration Agency of the Republic of Bulgaria, UIN 202946275, having its registered address and office in Sofia, No.73, Stamboliiski blvd. (hereinafter ALD Automotive).
The Data Protection Officer for the ALD/SGEB Group in Bulgaria is Daniela Hristova, dpo@socgen.com, and ALD Automotive’s Data Protection Correspondent is Mariana Kurteva, gdpr.bg@aldautomotive.com.
 

General principles

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 endeavor 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 only as long as you enjoy a business relationship with ALD Automotive, or the term applicable under local law since our last contact, or as required to comply with ALD Automotive’s legal obligations.
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.
 
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’s Data Protection Correspondent: Mariana Kurteva, gdpr.bg@aldautomotive.com, and /she will respond.
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. Where possible, we will provide remote access to a secure system which would provide you with direct access to your personal data.
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 defense 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.
 
Am I required to provide Personal Data?
As a general principle, your granting of any consent and your provision of any personal data hereunder for processing based on the data subjects consent is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which ALD Automotive cannot take action without certain personal data, for example because this personal data is required to process your inquiries, your orders or provide you with access to an offering or newsletter. In these cases, it will unfortunately not be possible for ALD Automotive to provide you with what you request without the relevant personal data.
Please refer to the “How do we use your personal information?” section below for details on data processing purposes and legal grounds of such processing.
 
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, third-party sources, 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: drivers of leased cars, business-to-business customers’ contact, partners, dealers, geographical partners, prospects, fleet managers, shareholders, managers, representatives and contact persons for our clients, suppliers and service providers, etc.
 
Who controls the data?
In Bulgaria, ALD Automotive EOOD carries out the data processing activities described above. This section applies to the processing of your personal information by ALD Automotive EOOD as data controller.
At ALD Automotive EOOD, the Data Protection Correspondent responsible for your personal information is Mariana Kurteva, gdpr.bg@aldautomotive.com
 
How do we use your personal information?
ALD Automotive EOOD uses your personal information to offer you better services.
Therefore, ALD Automotive EOOD may use your personal information in the following cases:
(a) When necessary for contractual purposes
(i) on a general level, to manage the commercial relationship with you and your company, respond to estimate requests, open customer accounts, fulfill your orders for services and for related activities, manage events, send you communications related to your contract, respond to your inquiries and requests for verifications, provide customer service, account management, support and related training of our personnel involved in such activities, and to provide other services related to your account.
(ii) for the purposes of international customer relationship management  in the context of car leasing activities by ALD Automotive Group affiliates, with clients being managed by our parent company ALD SA (France) 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;
(b) When necessary for the purposes of the legitimate interests pursued by ALD Automotive:
(i) to provide customer satisfaction surveys to professional traders about the remarketing of leased cars service and to customers (including fleet managers and drivers) for the purposes of continuous improvement of our services.
(ii) 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.
(iii) recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, ALD Automotive may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of ALD Automotive’s services;
(iv) in the context of ALD’s Know Your Client (KYC) policy and with the aim of maintaining legitimate and trustworthy business relations, ALD may process personal information from publicly available sources about legal and other representatives, board members and ultimate shareholders of its clients.
(c) With your informed knowledge and consent
(i) Marketing purposes: 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 analyze your client profile and preferences, and perform multichannel marketing campaigns via automated tools, contact you via SMS, email, or send you brochures; 
(ii) We may also invite you to participate in marketing events, games, or quizzes, through our mobile applications and/or websites.
(iii) 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 analyze 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.
We also use cookies for web analytics to measure the web sites activity and determine the areas of the web sites which are the most visited.
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.
(iv) 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
(d) When necessary for compliance with a legal obligation to which ALD Automotive is subject
(i) to perform customer screening and customer rating of ALD’s counterparties in the context of its obligations under the effective anti-money laundering legislation;
(ii) we use your personal information to maintain business records for legal, administrative and audit purposes. We also use information to meet legal, insurance and processing requirements.
 
What type of personal information do we collect?
We collect the following types of personal information:
· Identification and Contact information, such as your name, last name, city, telephone/mobile number or email address;
· Professional information, such as your job title or professional address;
· Financial/Credit information, such as your Credit Acceptance Date or contract information;
· Private details: such as your gender, date of birth, nationality, language(s), or personal preferences (habits, favorite car, etc.);
· Your voice when you call ALD Automotive customer services since your call may be recorded;
· Driver data, such as the number/copy of the driver's license, or the employee code driver;
We may also collect information about you indirectly from our business partners 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 make a purchase), or passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).
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 behavior.
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.
   
Vehicle Operations
When your company uses car leasing services with us, we may collect information about the vehicle (such as the vehicle registration plate, or the vehicle last revision) and the driver's behavior (such as the average speed) and his/her personal data (such as identity card and driving license), to provide the car leasing services in accordance with the contract and invoice you or your company].
 
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, call centers, data administrators, insurers, insurance brokers, rent-a-car companies, and other service providers contracted in the context of the car leasing agreement, located in Bulgaria or within the European Economic Area and instructed to only use your personal information in accordance with our instructions.
· with unaffiliated marketing partners, but only if you have given us your consent.  
· 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, or as needed support external auditing, compliance and corporate governance functions. 
· 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’s Data Protection Correspondent: Mariana Kurteva, gdpr.bg@aldautomotive.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 (in countries such as Algeria, Belarus, Brazil, Chile, China, Colombia, India, Kazakhstan, Mexico, Morocco, Peru, Russia, Serbia, Switzerland, Turkey and Ukraine 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 the provision of 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 long do we keep the personal information?
We retain your personal information collected for the purposes and under the conditions described in the General Conditions section above and for a duration limited to what is strictly necessary.
 
How can you contact us or the supervisory authority to lodge a complaint?
If you have any questions, complaints, or comments regarding this Data Privacy Policy or our information collection practices, please contact us by writing, or sending an email to: ALD Automotive’s Data Protection Correspondent:  Mariana Kurteva, gdpr.bg@aldautomotive.com.
You can also lodge a complaint with the 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.
What happens when we change this Data Privacy Policy?
Our Data Privacy Policy may change from time to time to reflect changes in the way we processing your personal information. However, these changes will remain fully compliant with applicable law. We encourage you to periodically review this page for the latest information on our privacy practices. We will notify you of any material changes as required by law.
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