General Addax Privacy & Data Protection Policy
ADDAX MOTORS NV (“Addax”) respects your privacy. Whether you deal with Addax as a customer, a user, a member of the general public, etc. you are entitled to the protection of your Personal Data.
This Policy explains which data we collect, how and why we collect them, what we do with them, with whom we share them, and how we protect them. It also explains the choices you can make about your Personal Data and how you can contact us if you have any questions, comments or concerns.
By providing information to us or by using our products or services, you agree to the terms and conditions of this Policy.
WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA
The entity which is responsible for the Processing of your data is:
Addax Motors NV
Kleine Tapuitstraat 18
HOW TO CONTACT US
To contact us with questions or comments or complaints, to opt out from certain services, or to exercise your rights described in this Policy, you may contact us:
- email@example.com; or
- Addax Motors NV
Attention Data Protection Contact Point
Kleine Tapuitstraat 18
WHICH DATA DO WE COLLECT
The following categories of Personal Data can be collected via the services and channels described in this Policy:
- Contact details: Name, phone number, e-mail address, billing address, VAT number, etc.
- Other Personal Data: IP-address, VIN, browser language, browser version, etc.
- Use of websites and communication: Information on how you use the website, including data gathered via cookies and other tracking technologies.
To improve our vehicles and service for you, we also collect certain telematics data regarding the performance, usage, operation, and condition of your Addax vehicle.
Telematics log & remote analysis data: To improve our vehicles and services for you, we collect certain telematics data regarding the performance, usage, operation, (geo-)location and condition of your Addax vehicle
If you no longer wish us to collect telematics log data or any other data from your Addax vehicle, please contact us as indicated in the “HOW TO CONTACT US” section above. Please note that if you opt out from the collection of telematics log data or any other data from your Addax vehicle, we will not be able to notify you of issues applicable to your vehicle in real time. This may result in your vehicle suffering from reduced functionality or inoperability, and it may also disable many features of your vehicle including periodic software and firmware updates, remote services, etc.
FOR WHICH PURPOSE DO WE PROCESS THE PERSONAL DATA THAT WE COLLECT
We will only process your Personal Data for specified, explicit and legitimate purposes and we will not process your Personal Data further in a way that is incompatible with those purposes.
We may use the data we collect for the purposes listed below:
Ø To communicate with you
We may use information we collect to communicate with you, including:
- To respond to your inquiries and fulfill your requests, such as to send you newsletters or product information, information alerts, information about events, or brochures
- To set up, evaluate, and provide feedback regarding your Addax test drive
- To send administrative information to you, such as information regarding our products and services, and changes to our terms & conditions, and policies
Your communication choices:
- If you no longer want to receive marketing-related e-mails from us or our affiliates, you may opt out of receiving them by following the opt-out instructions in any marketing e-mail received from us or by contacting us at the address mentioned above.
- If you receive a marketing-related call from us and do not want to receive similar calls in the future, simply ask to be placed on our “do not call” list.
Ø To provide and improve our products and services
We may use information we collect to provide and improve our products and services, including:
- To complete and fulfill an order you have placed
- To provide service to your Addax vehicle
- To monitor your Addax vehicle’s performance
- To advise you of important safety-related information about your vehicle
- To develop and promote new products and services, and to improve or modify our existing products and services
- To analyze and improve the safety and security of our products and services
- To deliver any other services you have requested
Ø For other purposes
We may also use information that we collect for other purposes, including:
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
- Except as described above and below, Addax may use or share information that does not personally identify you for any purpose, such as for operational or research purposes, for industry analysis, to improve or modify our products and services, to better tailor our products and services to market’s needs, and where legally required.
ACCESS TO AND KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE
You have the right to access your Personal Data which we are Processing and, if your Personal Data is inaccurate or incomplete, to request the rectification or erasure of your Personal Data. If you require further information in relation to your privacy rights or would like to exercise any of these rights, please contact us as indicated in the “HOW TO CONTACT US” section above.
It is important for us to maintain accurate and up-to-date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting us as indicated in the “HOW TO CONTACT US” section above. We will take action to make sure that any inaccurate or outdated Personal Data is deleted or adjusted accordingly.
We keep your Personal Data for the period necessary to fulfill the purposes for which we process your Personal Data or to comply with the law.
For information on how long certain Personal Data is likely to be kept before being removed from our systems and databases, please contact us as indicated in the “HOW TO CONTACT US” section above.
HOW DO WE PROTECT YOUR PERSONAL DATA
We have a set of technical and organizational security measures in place to protect your Personal Data against unlawful or unauthorized access or use, as well as against accidental loss or damage to their integrity. They have been designed taking into account our IT infrastructure, the potential impact on your privacy and the costs involved and in accordance with current industry standards and practice.
Maintaining data security means protecting the confidentiality, integrity and availability of your Personal Data:
- Confidentiality: we will protect your Personal Data from unwanted disclosure to third parties.
- Integrity: we will protect your Personal Data from being modified by unauthorized third parties.
- Availability: we will ensure that authorized parties are able to access your Personal Data when needed.
Our data security procedures include: access security, backup systems, monitoring, review and maintenance, management of security incidents and continuity, etc.
Your Personal Data will only be processed by a third party Data Processor if that Data Processor agrees to comply with our technical and organizational data security measures.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your Personal Data is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “HOW TO CONTACT US” section above.
If you sell or transfer your Addax vehicle to another person, please notify us so that we can determine whether additional steps are required to help safeguard information from or about you from disclosure to the purchaser or transferee of the Addax vehicle.
DISCLOSURE OF PERSONAL DATA
Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, which will then process your Personal Data only within the framework of these purposes:
Ø Our organization and service providers
- Addax authorized staff members
- Authorized members of our distribution and service network which you have indicated as your dealer or service provider (via the settings of your My Addax account – which can be changed at any time), or which are located near you, or which you have been in contact with
Ø Third party business partners and third parties you authorize
- Advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions
- With our third party service providers to provide services such as website hosting, data analysis and storage, payment processing, order fulfillment and product installation, wireless connectivity to Addax products, information technology and related infrastructure, customer service, product design, product diagnostics, maintenance or related services, e-mail delivery, auditing, marketing, voice command processing, and other similar services
- With other third party business partners to the extent that they are involved in the purchase, lease, or service of your Addax vehicle
- With third party service providers, if you choose to utilize them
Ø With other third parties when required by law
- when required by law or as lawfully necessary to protect us:
- to comply with the law, requests from authorities, court orders, legal procedures, obligations related to the reporting and filing of information with authorities, etc.
- to verify or enforce compliance with our policies and agreements; and
- to protect our rights, property or safety and/or our customers
- in connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of our business, or otherwise in connection with a merger, consolidation, change in control, reorganization or liquidation of all or part of our business.
TRANSFER OUTSIDE THE EEA
Your Personal Data may be transferred to recipients which may be outside the EEA, and may be processed by us and these recipients outside the EEA. In connection with any transfer of your Personal Data to countries outside the EEA that do not generally offer the same level of data protection as in the EEA, WE will implement appropriate specific measures to ensure an adequate level of protection of your Personal Data.
INDIVIDUALS LOCATED OUTSIDE THE EEA
In some countries outside the EEA, for example Switzerland, the EU has already determined a level of data protection comparable with that in Europe. The comparable level of data protection means that data transfer from or into these countries does not require any special permission or agreement.
RIGHTS AND CHOICES
We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data
Ø Your choices on how you want to be contacted
In this context, you can make a variety of choices about how you want to be contacted by us, through which channel (for example, email, mail, social media, phone…), for which purpose and how frequently, by adjusting the privacy setting on the relevant device or updating your user or account profile or by following the unsubscribe instructions included in the communication.
Please note that by default, if you don’t make a choice, you will receive our promotional communications at the normal frequency of the publication involved.
Ø Your Personal Data
You may always contact us as indicated in the “HOW TO CONTACT US” section above to find out what Personal Data we have concerning you. Under certain conditions, you have the right to receive your Personal Data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your Personal Data to any third party of your choice.
Ø Your corrections
If you find any mistake in your Personal Data or if you find it incomplete or incorrect, you may also require from us that we correct or complete it.
Ø Your restrictions
You have the right to request a restriction on the Processing of your Personal Data.
Ø Your objections
You may also object to the use of your Personal Data for direct marketing purpose or to the sharing of your Personal Data with third party for the same purpose.
You may withdraw your consent at any time to the continued Processing of the Personal Data that you have provided to us by contacting us as indicated in the “HOW TO CONTACT US” section above.
Moreover, you may require us to erase any data concerning you (except in some cases, for example, to prove a transaction or when required by law).
Finally, you have the right to file a complaint with the Belgian Data Protection Authority.
UPDATES TO THIS POLICY
Last Updated August 2018
 Personal Data is any data relating to you directly or which allows your identification, such as, for example, your name, telephone number, email address, Vehicle Identification Number (VIN), (geo-)location, etc.
 Processing means the collection, accessing and all forms of use of your Personal Data
 Data Processor means the person or organization which processes your Personal Data on behalf of Addax Motors NV.
 EEA means the European Economic Area (= member states of the European Union + Iceland, Norway, and Liechtenstein).