PRIVACY POLICY
Last update : March 12th 2019
Last update : March 12th 2019
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This privacy policy will inform you of the nature of the personal data about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This privacy policy is intended to assist you in making informed decisions when using the Sites and interacting with us. Please take a moment to read and understand it.
This privacy policy should also be read in conjunction with our Website Terms of Use. It only applies to the use of your personal data obtained by us and does not apply to your personal data collected during your communications with third parties.
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Axodel provides its services to Partners through the following companies :
Kuantic SAS is a French company with registered office (31700) Blagnac, 2b rue Marcel Doret – Burolines – Building 2 RCS Toulouse 797 521 242
Axodel Limited is an English company with registered office 8th Floor South, 11 Old Jewry, London, United Kingdom, EC2R 8DU
AXODEL Bvba is a Belgium company with registered office Brouwersvliet 37, 3de verdieping, Antwerpen, Belgium
Axodel IBERICA Sociedad Limitdada is a Spanish company with registered office C/Pau Claris Nº138 7º 2ª C.P.08009 (Barcelona), Spain.
AXODEL ITALIA srl . Environment Park Via Livorno, 60 10144 TURIN, Italy
Please contact the relevant Partner to find out which of these companies is your data controller. Alternatively, you can contact us using the details below below – please see How to contact us.
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We may collect, use, store and transfer different kinds of personal data about Users of Vehicles in connection with our provision of the Telematics Services, which we have grouped together as follows:
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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows :
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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Nous pouvons collecter, utiliser, conserver et transférer différents types de données personnelles au sujet des Utilisateurs des Véhicules, en rapport avec les Services télématiques que nous fournissons. Nous avons groupé lesdites données de la manière suivante :
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We use different methods to collect data from and about you including through:
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We collect and maintain User Data and Telematics Data to provide our Partners with the particular services that they have requested.
Who do we share your personal data with for this purpose ?
User Data and Telematics Data is shared with the Partner that has made the Vehicle available to the User that the personal data relates to. To find out more about how and why your personal data is processed by our Partners, please contact the relevant Partner that has made a Vehicle available to you.
We will also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.
What is our legal basis ?
It is in our legitimate interest for us to use your personal data to perform our obligations in accordance with any contract that we have with our Partner.
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We collect and maintain Identity Data, Profile Data, Contact Data, Financial Data and Transaction Data so that we can enter into, administer and perform contracts that we have with Partners for the provision of our Telematics Services:
Who do we share your personal data with for this purpose ?
We will share your personal information with the following categories of third parties:
We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information
What is our legal basis ?
It is in our legitimate interest to use your personal data so that we can perform our obligations in accordance with any contract that we have with our Partner.
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In order to receive the Telematics Services, our Partners’ personnel may need to register and create accounts for access to restricted areas of our Site. In doing so, we will ask for Profile Data to be submitted to us and we may combine this data with other data, including your Contact Data, to manage your account.
Who do we share your personal data with for this purpose ?
We do not share your personal data with third parties for this purpose.
We may share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.
What is our legal basis ?
It is in our legitimate interest to use your personal data in such a way to ensure that we can deliver our Telematics Services to our Partners.
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We use various user interfaces to allow you to request information about our products and services. These include printed and electronic enquiry forms and a telephone enquiry service. Contact Data may be requested in each case, together with details of other personal data that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.
Who do we share your personal data with for this purpose ?
We do not share your personal data with third parties for this purpose.
We may share your personal data within our group of companies Please see Who are we and who is responsible for your data? for further information.
What is our legal basis ?
It is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best customer service we can to you.
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From time to we may use your Contact Data to invite you to provide feedback about our services in the form of electronic or postal surveys or to provide a review or endorsement. We use this information to help us improve the quality of service provided us. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.
Who do we share your personal data with for these purposes?
We use a third party service provider to assist us with customer surveys and feedback requests.
We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.
What is our legal basis ?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
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We receive and/or gather Usage Data by analysing your Contact Data with other personal data that we observe about you from your interactions with our Sites, our email communications to you and/or during our supply of Telematics Services.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect the Technical Data described above.
Our web pages [and e-mail]s contain “cookies” “web beacons” or “pixel tags.” (“Tags”) which allow us to track [receipt of an e-mail to you], to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. [Once you click on an e-mail that contains a Tag, your Contact Data may subsequently be cross-referenced to the source e-mail and the relevant Tag].
[In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications].
Please see our Cookie Policy for further information.
This information is used to create profiles and insights about your browsing habits and the browsing habits of our other users to our Sites.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our services. This allows us to learn what pages of our Sites are most attractive to our visitors and which parts of our Sites are the most interesting.
We also use this information to help us with the selection of future product and service lines and websites design.
Who do we share your personal data with for these purposes ?
We do not share your personal data with third parties for this purpose.
We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data ? for further information.
What is our legal basis ?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other customers.
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We carry out the following marketing activities using your personal data, including your Contact Data and Marketing and Communications Data.
Who do we share your personal data with for these purposes?
We share your personal data with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.
We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? Who are we and who is responsible for your data?
What is our legal basis ?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal data for postal marketing.
Who do we share your personal data with for these purposes ?
We do not share your personal data with third parties for this purpose.
We may share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.
What is our legal basis ?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
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We use your personal data for the following business administration and legal compliance purposes:
Who do we share your personal data with for these purposes?
We will share your personal data with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data?
What is our legal basis ?
Where we use your personal data in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
We do not transfer your personal data outside the European Economic Area.
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Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy policy applies solely to personal data collected by us and does not apply to these third party websites and third party service providers.
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We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from :
All of our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data that we control.
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If you ask us, we’ll confirm whether we’re processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
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If the personal data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
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You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
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You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. It won’t stop us from storing your personal data though. We’ll tell you before we lift any restriction. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
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With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
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You can ask us to stop processing your personal data, and we will do so, if we are.
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You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
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If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
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If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the [UK Information Commissioner’s Office (ICO]). You can find details about how to do this on the [ICO] website at [https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113].
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To ensure that you are always aware of how we use your personal data we will update this privacy policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this privacy policy periodically to be informed of how we use your personal data.