AUTO-SUECO, LDA. Privacy Policy

AUTO-SUECO, LDA. (“AUTO-SUECO”), a NORS Group company, hereby informs you of its Privacy Policy, which explains your rights and how it collects and uses your personal data.

We at AUTO-SUECO are committed to using your data only for clearly defined purposes, and we adopt a number of technical and organisational security measures to protect personal data made available to us from disclosure, loss, unauthorised use, alteration, unauthorised processing or access, and any other form of illicit use.

  1. Data Controller

AUTO-SUECO, with head office at Via Marechal Carmona, 1637, 4100-189 Porto, is the Data Controller, because it is the company who determines what data are collected, how they are processed and the purposes for which the data are used.

As an importer of Volvo lorries, buses and marine engines, AUTO-SUECO suggests you to read Volvo’s privacy policies, since Volvo may also collect your personal data. You should contact Volvo directly in relation to any question concerning the use it makes of your personal data.

  1. Data Protection Officer

AUTO-SUECO has a Data Protection Officer (DPO), who (i) supervises and advises the controller in respect of their obligations under the rules of privacy and protection of personal data, (ii) cooperates with the supervisory authority, (iii) is the contact point with the client, or potential client, in order to clarify possible questions about data processing by AUTO-SUECO.

Should you wish to clarify any doubts or lodge a complaint, you can do so to the AUTO-SUECO data protection officer by e-mail at dpo@nors.com

You also have the right to lodge a complaint to the National Data Protection Commission (CNPD) regarding the processing of your personal data byAUTO-SUECO.

  1. Personal data, data subjects, categories and method of collecting personal data
    • What are personal data?

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier. An identifier may be a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • Who are the data subjects?

The customer or potential customer, a natural person, to whom the data relate and who uses, or intends to use, the products or services made available byAUTO-SUECO.

The representative/employee or point of contact within the company, in the case of corporate bodies, in the performance of a contract, or the steps taken prior to entering into a contract, entered into between that company and AUTO-SUECO.

  • What categories of personal data are processed by AUTO-SUECO?
IDENTIFICATION DATA EXAMPLES

 

PERSONAL AND CONTACT INFORMATION Civil or fiscal identification data, telephone number, address, e-mail address, among others.
DATA RELATING TO THE PURCHASE OF PRODUCTS AND SERVICES Product or service purchase history.
CUSTOMER HISTORY Information related to contracts entered into; responses to satisfaction surveys; offers received; campaign history; participation in events; history of complaints, etc.
  • How and when are your personal data collected?

The data subject’s personal data may be collected under the following circumstances:

  1. For the purposes of entering into or performing a contract, specifically, when the data subject purchases a product and/or service from us.
  2. Through the AUTO-SUECOwebsite or that of the brand we represent.
  3. When the data subject goes to one of our points of sale and makes their personal data available to us.
  4. When the data subject gives consent by subscribing to our newsletters.
  5. When the data subject takes part in events organised by AUTO-SUECO, or by the brands we represent, making their personal data available to us.
  6. Basis, Purpose and Duration of the Processing of Personal Data

The legal basis for AUTO-SUECO to process the data subject’s personal data are as follows:

Consent: the data subject’s personal data may be processed by means of a free, specific, informed and unambiguous expression of will, according to which they accept, by statement or by a clear affirmative action, that their personal data be processed.

Steps taken prior to entering into a contract and/or performance of contract: the data subject’s personal data may be required for handling queries, to present them with a proposal for entering into a contract and for the performance and management of a contract with ALTO-SUECO.

Compliance with legal obligations: the data subject’s data may be required to comply with a legal obligation to which the controller, in this case AUTO-SUECO, is subject.

Legitimate interest: the data subject’s data may be required for the performance of certain operations related to AUTO-SUECO’s business, except when their privacy and data protection rights must prevail.

AUTO-SUECO will process the data subject’s personal data as follows:

LEGAL BASIS                                                                                                         PURPOSE

CONSENT We process the personal data of customers and potential customers on the basis of their consent, for commercial and marketing purposes, namely: marketing campaigns, events, promotions, information about new products, satisfaction surveys on services provided by AUTO-SUECO
STEPS TAKEN PRIOR TO ENTERING INTO A CONTRACT AND/OR CONTRACT

PERFORMANCE

We process personal data for the purposes of entering into, performing and managing contracts between the customer and AUTO-SUECO.
LEGAL

OBLIGATIONS

When processing is required for compliance with legal obligations, the data subject’s personal data will be transmitted to official bodies, for example, for billing purposes, or for responses to and the resolution of any complaints recorded in

the Complaints Book, etc.

LEGITIMATE INTEREST We process personal data based on legitimate interest, particularly to monitor and manage the business; in the context of a customer’s request for contact via the website, through social networks, or by telephone or e-mail; to respond to complaints made and when we need to contact the representative of a corporate body, in the context of performing a contract or the steps taken prior to entering into a contract.

When the customer is a corporate body, in order to meet its contractual obligations,AUTO-SUECO must collect some personal data (name, e-mail and telephone number) of the representative or employee of that company, for the purpose of enabling the proper performance of that contract.

In this case, the corporate body must ensure the data collected from its suppliers/collaborators are collected and transmitted to AUTO-SUECO lawfully (under one of the legal grounds provided for in the applicable legislation) and must give data subjects, their representatives or employees, the right to information on how these data are processed.

  • Period for which personal data will be stored

AUTO-SUECO stores the data subject’s personal data only for the period strictly necessary for the purpose for which they were collected.

In certain cases, the law requires data to be stored for a specific period, in particular in the case of data necessary for the tax authority, which will be retained for 10 years, in accordance with current legislation.

We will also store the data subject’s data for as long as there is a contractual relationship withAUTO-SUECO.However, we may store the data subject’s personal data for periods longer than the duration of the contract, to guarantee the rights and duties relating to the contract or in situations in which AUTO-SUECOhas a legitimate interest while respecting the timescales necessary for the purpose for which they were collected.

In the absence of a specific legal obligation, the data subject’s data may be processed only for the period necessary to meet the purposes for which it was collected, and only for as long as there are legitimate grounds for its storage by AUTO-SUECO.

Once the maximum storage period has been reached, the personal data will be irreversibly anonymised (anonymised data may be stored) or securely destroyed.

  1. Transmission of your personal data

AUTO-SUECO transmits the data subject’s personal data only when necessary for the purposes described above, namely for the provision of services requested by them.

AUTO-SUECO‘s suppliers and/or service providers are contractually subject to the same terms and conditions for processing personal data and are prohibited from using, transferring, divulging or recording the data subject’s personal data for any other purpose than for which they were specifically hired (or without their consent, as applicable). When requested by the data subject, AUTO-SUECO may transmit their personal data, according to the purpose for which it was collected, to third parties, and only the data necessary for the activities carried out by these third parties shall be transmitted.

The data subject’s personal data may also be transmitted to bodies with whom there is a legal obligation to share this data: for example, to the tax authority.

  1. Link to other websites

Please note that AUTO-SUECOis not responsible for the privacy practices of third parties whose websites to which our website links, and cannot guarantee the accuracy or authenticity of the information contained therein. We encourage you to read the privacy policies of any other website linked to the AUTO-SUECO website.

AUTO-SUECO does not guarantee the accuracy, completeness or authenticity of the information contained in any hyperlink or other internet site. Personal data entered on other internet sites with links to the AUTO-SUECO website are the sole responsibility of the data subject.

  1. Rights of the data subject and responding to subject requests

AUTO-SUECO guarantees the applicability and fulfilment of all the data subject rights contained in the General Data Protection Regulation and national laws.

  • Right of Access

The data subject has the right to obtain from AUTO-SUECOconfirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to their personal data and information relating to that data. For example, the data subject may request an exact copy of the personal data undergoing processing and request additional information about the processing carried out.

  • Right to Rectification

The data subject also has the right to obtain from AUTO-SUECO without undue delay the rectification of inaccurate personal information, including the right to correct or complete their personal data.

  • Right to erasure (“right to be forgotten”)

The data subject has the right to obtain from AUTO-SUECOthe erasure of their personal data without undue delay, provided that: the data are no longer necessary in relation to the purposes for which they were collected and processed; when withdrawing consent and where there are no other legal grounds for their processing; when objecting to the processing and there are no overriding legitimate grounds for the processing on the part of AUTO-SUECO, as well as in other legally foreseen cases.

  • Right to Data Portability

The data subject has the right to receive personal data concerning them and which they have provided to AUTO-SUECO in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller (if this is technically possible), if the processing is based on consent or a contract, and if the processing is carried out by automated means.

  • Right to withdraw consent

The data subject may at any time change their consent, limit it to certain types of processing or withdraw it. However, withdrawal of consent does not compromise the lawfulness of processing carried out with their prior consent.

  • Right to Object

The data subject may also at any time object to the processing of personal data relating to them, where there are no compelling legitimate grounds for the processing which override their interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

The data subject has the right to object at any time to their data being processed for direct marketing purposes. In this case, AUTO-SUECO undertakes to stop processing data for that purpose.

  • Right to Restriction of Processing

In certain situations the data subject has the right to obtain from AUTO-SUECO restriction of processing, in particular, if they contest the accuracy of the personal data for a period enabling AUTO-SUECOto verify the accuracy of the personal data, when the personal data are no longer required for the purposes of processing, but they are required by the data subject for the establishment, exercise or defence of legal claims and when the data subject has objected to processing pending the verification whether the legitimate grounds of AUTO-SUECOoverride those of the data subject, as well as in other legally foreseen cases.

  • Right not to be subject to automated decision-making

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

  • Exercising these rights

The data subject may exercise their rights at no cost, except in the case of a manifestly unfounded or excessive request, in which case a reasonable fee may be charged to offset costs.

Except in the case of more complex requests, we will respond to your requests within 30 days.

The data subject may exercise their rights in one of the following ways:

  1. By letter addressed to the DPO, Grupo Nors, Rua Manuel Pinto de Azevedo no711, 1º, 4149-010 Porto, Portugal
  2. By e-mail to: dadospessoais@autosueco.pt

If, after exercising any of these rights, you are not satisfied with our response you have the right to lodge a complaint with the CNPD.

  1. Procedural Measures and Security Techniques

AUTO-SUECO employs physical, technological and organisational security measures that are adequate for the protection of personal data in order to protect the personal data made available to us from disclosure, loss, misuse, alteration, processing or unauthorised access, and against any other form of illicit processing.

To this end, AUTO-SUECOemploys technical and organisational measures that ensure a level of security that is appropriate to the risks involved in keeping personal data on file and during the transmission thereof.

AUTO-SUECO uses a computer system that can withstand, with a high level of confidence, accidental events or malicious or illegal actions that compromise the availability, integrity and confidentiality of the personal data stored or transmitted.

  1. Cookies

AUTO-SUECO uses ‘cookie’ technology to enable you to follow the links that led you to this site in order to help AUTO-SUECO record user activity on this site and to evaluate and improve the site in order to make it more useful for you. AUTO-SUECO does not use this technology to record information about individual users. Please note that you can change your browser settings to reject cookies or to warn you when you are being sent cookies.

  1. Use of the AUTO-SUECO website
  • Use of materials on the AUTO-SUECOwebsite and the information, text, figures or graphics contained therein are for personal use only and may not be used for commercial purposes, nor shall you reproduce, modify, transmit, authorize or publish this information, text, figures or graphics, in whole or in part, for any purpose without prior written consent fromAUTO-SUECO.
  • With respect to its use and risk of its use, AUTO-SUECO specifically disclaims any liability for direct, indirect, accidental, consequential or special damages arising out of, or in any way associated, with your access to or use of this site that affects your computer equipment, or your confidence in the information obtained through the AUTO-SUECO

The information concerning the website is available in its information section. Despite AUTO-SUECO‘s efforts to keep the contents up-to-date and reliable, they may contain inaccuracies, typographical errors or be out of date, and may be changed at any time and without prior notice by AUTO-SUECO.

  1. Updates to the Privacy Policy

AUTO-SUECO reserves the right to update this policy at any time, according to the legal requirements and/or the company’s commercial requirements. You are hereby invited to visit this page to see our policy.

This Privacy Policy was last updated on 22 May 2018.