UAB Hoobrid Privacy Policy
I. General provisions
By becoming and intending to become our customer, by visiting our website, by agreeing to receive our news and offers, by contacting us on any other matter, you are providing us with your data. The purpose of this policy is to disclose and explain to you the circumstances in which we collect and process your personal data; the types of data we collect; the reasons why we collect your personal data; and how we process your personal data.
Personal data means any information that can be used to identify an individual, as well as any information about an individual who has already been identified (details of personal data and the purposes of and grounds for processing personal data are set out in Part III of this Policy).
Processing means any operation or sequence of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, sorting, organisation, storage, adaptation or alteration, retrieval, access, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination with other data, restriction, erasure or destruction
Data Controller: UAB Hoobrid, company code: 305583008, VAT payer code: LT100013240319, registered office address / address for correspondence: Kaunas, Verslo g. 24-1. Contact person responsible for data protection: management@hoobrid.com
II. Principles of data processing
Hoobrid UAB respects your privacy and protects the personal data that you provide to us and that we collect, as set out in this privacy policy.
Hoobrid UAB is committed to ensuring that your data is processed in accordance with the following basic principles:
Lawfulness, fairness and transparency: the processing is lawful, fair and transparent in relation to the data subject;
purpose limitation: personal data are collected for specified, explicit and legitimate purposes and are not further processed in a manner incompatible with those purposes;
data minimisation: the processing is adequate, relevant and limited to what is necessary for the purposes for which it is processed;
Accuracy: data shall be processed accurately and, where necessary, kept up-to-date; all reasonable steps shall be taken to ensure that personal data which are not accurate in relation to the purposes for which they are processed are erased or rectified without delay;
limitation of the duration of retention: data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
integrity and confidentiality: data shall be processed in such a way as to ensure, through appropriate technical or organisational measures, adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Hoobrid UAB undertakes to ensure that your personal data is collected only in accordance with the procedures and on the grounds laid down by law, by obtaining it directly from you or through our partners whose services you will use, or by requesting it from the entities that process the necessary information and have the right to provide it, or by accessing, on the basis of contracts and the law, databases, registers and information systems that store individual data.
At the time of data collection, we will inform you separately of the identity and contact details of the controller; the purposes of the data collection; the persons (categories of persons) to whom the data may be disclosed; and any other relevant information, the disclosure of which is important to ensure the transparency of the processing of data. We will endeavour to provide all necessary information to the data subject in a clear and comprehensible manner.
RETENTION PERIOD. Your personal data will be processed for no longer than is necessary. The retention period of personal data is defined by the nature of the contracts concluded with the Customer, Hoobrid's legitimate interests or by legal requirements (e.g. those governing accounting, limitation period for claims, etc.).
When processing your personal data, Hoobrid UAB implements appropriate organisational and technical measures to protect your personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing. However, please note that although we take reasonable steps to protect your personal data, no website, online transaction, computer system or wireless connection is completely secure.
III. Personal data collected and purposes of their processing
We may process your personal data for the following purposes and areas:
Contract formation, performance and servicing
Direct marketing - providing you with a commercial offer to purchase our goods and services
Direct marketing - providing you with offers, invitations to events, other communications
Recruitment
handling enquiries, complaints, requests and feedback
debt management
cookies
data collected by the car
image data.
Purpose of processing: conclusion, performance and servicing of the contract. If you decide to become our customer (purchase a new or used car, enter into a test drive agreement, become a service customer or become a car rental customer), for the purpose of concluding, executing and servicing the contract, we will collect and process your personal data, which we will receive from you or from our partners whom you have contacted to initiate the contract, depending on the circumstances of the contract.
For this purpose, we will collect and process the following personal data:
name, surname, personal identification number, address, other contact information (email address, telephone number); if the client is a legal entity, the name, surname, position, contact information of the legal entity's representative - contact person;
date and time of conclusion of the contract,
details of the subject of the contract (the car to be purchased, repaired or leased, including its identifiers),
information on your solvency (details of your income, sources of income, existing financial obligations), contract security measures;
information on payment (method of payment, financial terms if payment is made by leasing, account from which payment is made),
details of the insurance contract concluded, the progress and history of claims management,
history of car breakdowns, maintenance, repairs, history of services provided to you.
Your personal data will be used primarily for the purpose of concluding and administering the contract. Depending on the circumstances of the conclusion of the contract, for the purpose of concluding and executing the contract, we may exchange information with other entities that are jointly involved in your service.
If you wish to obtain financing (a leasing offer) to finance your purchase, and you decide to manage this matter through Hoobrid UAB, in this case you will need to provide us with, and we will pass on to the relevant Leasing Partner, the information necessary to complete the leasing application, including information about your family composition, family income, financial obligations, your place of work, etc. Accordingly, as a result of the administration of the financing issue and the contact with the leasing company, Hoobrid UAB may make available to you information about your credit history, solvency assessment and other information which is held and administered by the relevant leasing partner. If you do not consent to such transfer of data, UAB Hoobrid will not be able to administer and mediate the conclusion of your financing agreement with the leasing company. In this case, you should contact the leasing company you prefer and secure a financing solution on your own.
In case you have contacted us for the repair of your car after an insured event and you wish us to mediate with the insurance company in the administration of the claim, we will pass on your profile data, information about your car, the damages and the repair history (if available to us) to the insurance company you have indicated. As a result of the administration of this service, we may have access to additional information - administered by the insurance company - about the terms and conditions of your insurance contract, the circumstances of its performance, the history of insured events etc.
Please be informed that UAB Hoobrid, as an authorised dealer and service provider, may pass on the data about the goods and services you have purchased to the respective supplier it represents. This data may include: your contact information (name, address, telephone number, email address, etc.); vehicle information (vehicle identification number (VIN), model, date of purchase); data relating to the purchase and use of products or services (customer preferences and preferences, purchase history, etc.).
Personal data about you and your car collected by the car manufacturer may be used by the manufacturer: (1) to provide you with products and services, including checking whether you are eligible for certain purchases and services, as well as providing you with extended offers and taking care of your impressions; (2) to inform you about news or changes to products or services, including, but not limited to, changes in terms and conditions and policies; (3) to inform you about new products, services, and events; (4) to provide you with assistance and services related to the car (after-sales service, recall information, etc.); (5) to provide you with information about the car and the services you have received; (6) to provide you with information about the car and the services you have received. (5) improving products, such as improving the dynamic performance, quality and safety of the car; (6) evaluating and improving offers and communications with customers; and (6) enforcing lawful claims.
Your personal data may be used to investigate your experience and the quality of customer service. For these purposes, your data may be processed both by Hoobrid UAB and by the manufacturer on whose behalf you were served. The survey may be carried out either by the data controller itself or by a specialised service provider. You have the right to refuse to take part in the survey without suffering any negative consequences.
In accordance with Article 69(2) of the Electronic Communications Act, we will use the email contact details you provide for the marketing of our similar goods or services. Please be informed that you will have the right to opt out of such use of your contact details at any time.
You may refuse the processing of your personal data by updating your preferences, discontinuing the use of a particular service, withdrawing your consent by contacting both the manufacturer and UAB Hoobrid at the contacts indicated in this policy. However, in any event, the manufacturer will not refuse to process your personal data in such cases and will process both on the basis of its legitimate interest and on the grounds that such processing is related to the protection of the vital interests of the data subject or of any other natural person arising from the need to ensure the safety of the vehicle:
(1) in relation to certain acts of collection and subsequent processing of data recorded by the car;
(2) when it is necessary to send you important notices, such as changes to terms or policies, or to recall a product, if necessary; and
(3) when it is done in compliance with legal obligations.
Direct marketing: providing news, promotions, invitations to events, offers.
For this purpose, we collect and process the following personal data: name, email address, telephone number, mailing address:
We need your name and surname so that we can know who we are contacting and to whom we are addressing the invitation to an event;
Your email address is needed to send notifications and invitations by email.
We suggest that you provide a telephone number so that we can make an offer or invitation to you by telephone if necessary;
if you wish to receive our supplier magazines by post, we will need your full name and postal address for this purpose.
The basis for processing the data is your CONSENT. You can decide and consent separately:
To receive news and offers from the selected car manufacturer we represent by email and/or telephone;
to receive invitations to events of the car manufacturer of your choice by email;
to receive the magazine of the car manufacturer we represent by post.
The data processing period (notification) is 1 year. After this period, if you do not renew your subscription, you will no longer receive notifications and invitations.
We will passively store your data for 1 year after your withdrawal of consent (basis: processing is necessary for the legitimate interests of the controller).
You may unsubscribe at any time by notifying us by email at management@hoobrid.com or by clicking on the link at the bottom of the notifications addressed to you.
Individuals under the age of 16 may not provide any personal data for marketing activities. If you are a person who is under the age of 16, you must obtain the consent of your parents or other legal guardians before you submit personal information for marketing purposes.
Direct marketing: making a commercial offer to you. If you contact our representative offices to receive an offer to purchase our goods and services, we will process the contact details and other information you have entrusted to us to prepare and submit the offer.
For this purpose, we collect and process the following personal data: the name, surname or other reference you provide to us, the email address, telephone number or other contact information you provide to us for the purpose of obtaining an offer, as well as information about the product or service you are interested in or any other criteria you provide to us that influence your choices.
The basis for processing the data is your CONSENT. We will consider your consent to have been obtained when you contact us and instruct us to make you an offer for the purchase of goods or services.
Term of processing - until the purpose of the processing is achieved, unless you withdraw your consent earlier.
Where the basis for processing is your consent, you may withdraw any consent you have given at any time by notifying us at management@hoobrid.com or at UAB Hoobrid, Verslo g. 24-1, Kaunas.
Persons under the age of 16 may not provide any personal data for marketing activities. If you are a person who is under the age of 16, you must obtain the consent of your parents or other legal guardians before providing personal information for marketing purposes.
Purpose of processing: handling enquiries, complaints, requests and feedback
Personal data: identification and contact information provided by the Customer: name, surname, telephone number, email address, residential address, date of birth; Content of the enquiry: the event that has been the subject of the enquiry, its circumstances, date, location, the Customer's request, claim or feedback, the product or service, other information contained in the enquiry; Other documents and/or data provided with the enquiry: e.g. purchase details, photos.
The Enquiry may be submitted by email, post, private message on social networks.
Basis:
1) Consent (at the time of the request)
2) The processing is necessary for compliance with a legal obligation to which the controller is subject
3) The processing is necessary for the purposes of the legitimate interests of the controller.
Data retention period: 12 months. If a legal dispute is initiated or is likely to be initiated in relation to the Enquiry, we may keep your data for a longer period of time, until the expiry of the statutory limitation periods for lodging a complaint or bringing an action and/or until the final judgment has become final and has been enforced.
We only use your data to enable us to process your Enquiry properly and objectively, to provide you with the information you require, to answer your questions, and to resolve your requests or claims. For this purpose, it may be necessary to contact third parties to collect additional information and therefore certain data from the Enquiry may be disclosed to them.
Hoobrid UAB does not disclose information about its correspondence with its customers. However, if a customer's enquiry or complaint is received in public comment forms on websites or social networking sites, UAB Hoobrid reserves the right to make the response/comment public in the same form as the enquiry was received.
After the expiry of the period of processing and retention of your data set out in this Policy, we will destroy or reliably and irreversibly depersonalize your data as soon as possible within a reasonable and prudent period of time for such action. Hoobrid UAB will not be able to comply with this requirement if the request is made through websites/social networking accounts not administered by Hoobrid UAB.
Purpose of processing: debt management. Subject to the progress of the execution of the concluded contracts, where there are legitimate grounds for doing so, the Customer Data collected for the purpose of concluding and executing the contracts may continue to be used for the purpose of managing arrears.
For this purpose, the following data are processed and additionally collected: name, surname, personal identification number, place of residence, financial situation, income and liabilities, marital status, presence of dependants, employment or other activities, legal proceedings initiated or concluded against you, other creditors.
The data are collected by obtaining them directly from you or by requesting them from entities that process the necessary information and have the right to provide it, or by accessing databases, registers and information systems collecting individual data on the basis of contracts and legal acts.
The processing is carried out in the legitimate interests of the controller and the consent of the individual is not required for the processing of such data.
The data may be disclosed to persons providing legal and other debt management services, including entities purchasing claim rights, as well as to courts, bailiff's offices and other persons who may need to disclose the information in order to pursue the legitimate interests of UAB Hoobrid.
Data retention period: until the purposes of the processing are achieved.
Staff selection.
For this purpose, we process the personal data (name, contact telephone number, email address and CV) of candidates who have sent their CV directly to us by email or via job portals in order to enable us to carry out the selection of candidates for the job position.
The basis for the processing of the data is your consent, which you express by submitting your CV.
In the course of selection for a job position, we only process candidates' personal data that relate to qualifications, professional skills and business characteristics. We do not collect and process candidates' special personal data or personal data relating to convictions and criminal offences.
At the end of the selection period for a specific position, we delete CVs and other data sent by candidates, unless we have obtained the candidate's consent to process his/her personal data for a longer period of time in order to be able to offer the job position. In this case, we will keep the candidate's personal data for 1 year.
Image data.
The premises of Hoobrid UAB, including areas where visitors are received (building access, outdoor parking, entrance, customer reception and service areas) are filmed.
The purpose of the surveillance is to ensure the protection of the employees of UAB Hoobrid, its property, including those located in the vicinity of the buildings, as well as the property of other persons.
The processing period (duration) of the video surveillance data is up to 14 calendar days, depending on the capacity of the video recording device. In the event that the relevant recording also records an offence or other information justifying and justifying the longer use of that recording, the time limit for the processing of the video surveillance data shall be extended to the extent necessary for the reasonable purpose of the use of the relevant recording.
Hoobrid UAB undertakes not to disclose the processed personal and video data to third parties, except in cases where such provision of personal and/or video data to third parties is expressly provided for in these Rules or where such provision of such data to third parties is permitted by the legislation of the Republic of Lithuania, in accordance with the procedure set out in the legislation of that Republic.
Upon a reasoned request from law enforcement authorities, court and other bodies with legitimate and justified interest, justifying the purpose of the use of the data, personal data and image (copy) captured by CCTV cameras may be released without the consent of the persons who provided the personal data / captured in the image, and without informing them of the provision of their data.
Cookies. When you visit the Data Controller's websites, we want to provide you with content and features that are tailored to your needs. To this end, our e-shop uses cookies. These are small pieces of information that are stored in your web browser. They help the Data Controller to recognise you as a previous visitor to a particular website, to store your visit history and to tailor the content accordingly. Cookies also help to ensure the smooth running of websites, to monitor the duration and frequency of visits to websites and to collect statistical information about the number of visitors to websites. By analysing this data, we can improve our websites and make them more user-friendly for you.
Cookies are used to make it more convenient for you:
Remember your settings;
Make it easier to log in to your account;
Returning to find the items you put in your basket;
To improve the content on our website.
We hope this works for you. If you change your mind in the future, you can change your browser settings and delete the cookies you have saved.
Types of cookies:
Functional cookies (essential). These cookies are essential for the functioning of the website and cannot be disabled. These cookies do not store any personally identifiable data and are deleted when you leave the website.
Performance cookies. These cookies allow us to calculate website traffic and traffic sources so that we can learn about and improve website performance. They help us to distinguish which pages are the most popular and to see how users use the website. We use the Google Analytics statistics system to do this. We do not distribute the information we collect. The information collected is completely anonymous and does not directly identify you.
Promotional cookies. These cookies are used by third parties to enable us to provide advertising that is relevant to your needs. We use cookies to collect information about your online activities and to learn what you are interested in, so that we can provide you with advertising that is relevant to you.
III. Provision of data to third parties
We keep your data secure and do not disclose it to third parties except where necessary. Your data processed by us may be disclosed:
To service providers / data processors who provide services and process your personal data on behalf of and on behalf of Hoobrid UAB as data controller (e.g. IT service providers, auditors, legal and financial advisors, cloud service providers, etc.), Other persons involved in the provision of goods and services, such as archivists, postal service providers, payment administration service provider, etc,
Public bodies and authorities, other persons exercising functions assigned to them by law, other third parties where required by applicable law or where necessary to protect the legitimate interests of Hoobrid UAB (e.g. courts, government and law enforcement authorities, etc.),
debt collection companies to which claims on the debt are assigned, courts, out-of-court dispute resolution bodies, insolvency administrators.
In each case, the data provided to the processor shall be limited to what is necessary for the execution of the specific order or the provision of the specific service.
The processors we use may only process personal data on our instructions and may not use it for other purposes or transfer it to other persons without our consent. They must also ensure the security of your data in accordance with applicable law and written agreements with us.
If Hoobrid UAB uses a website analytics service (e.g. Google Analytics) which is used to determine how you use the information provided on the website www.Hoobrid.com, we may exchange your personalised data with third parties who rely on this information for the purpose of evaluating the use of the website, compiling reports for website operators on the performance of the website, and for the purpose of providing other services relating to the use of the website, the web and the mobile application.
IV. Transfer of data to third countries
As a general rule, data is processed within the territory of the European Union/European Economic Area, but in certain cases it may be transferred to and processed outside the EU/EEA.
Personal data may be transferred and processed outside the EU/EEA where the transfer is necessary for the conclusion and performance of a contract or where the Customer has given his/her consent, and where appropriate safeguards are in place. Appropriate safeguards include:
A contract that includes standard terms and conditions adopted by the EU Commission or other approved clauses, codes of conduct, certificates, etc. approved under the General Data Protection Regulation;
The non-EU/EEA country in which the recipient of the Personal Data is located ensures an adequate level of protection of personal data as decided by the EU Commission;
The recipient is certified in accordance with the requirements of the Data Protection Agreement between the EU and the United States of America (USA) (also known as the 'Privacy Shield') (applicable to recipients located in the USA).
V. Rights of the data subject
The Data Subject whose data is processed in the course of the Data Controller's business has the following rights:
to know (be informed) about the processing of his/her data (right to know);
to have access to his/her data and how they are processed (right of access);
to request the rectification or, taking into account the purposes of the processing of personal data, the completion of personal data which are incomplete (right to rectification);
to have your data erased or to stop processing (other than storage) (right to erasure and right to be forgotten);
require the Data Controller to restrict the processing of personal data on one of the legitimate grounds (right to restrict);
the right to data portability (right to portability);
the right to object to the processing of his/her personal data or to withdraw his/her consent at any time to the processing of personal data for one or more specified purposes, without prejudice to the lawfulness of the processing based on consent prior to the withdrawal of consent;
lodge a complaint about the processing of personal data with the State Data Protection Inspectorate (www.ada.lt) if you consider that your personal data are processed in breach of the legal requirements.
For all questions concerning data processing and implementation of the data subject's rights, please contact UAB "Hoobrid", Verslo g. 24-1, Kaunas; management@hoobrid.com.
In order to protect the data of other persons from unlawful disclosure, upon receipt of a request for data or to exercise other rights, the data controller has the right to take additional steps to identify a person, such as requesting other profile data or sending a control message to an available contact to request an authorisation action. If the verification procedure is unsuccessful, the controller has the right to reject the request.
Upon receipt of a request for the exercise of any right and successful completion of the above verification procedure, the request will be processed within one month of receipt of your request and completion of the verification procedure. Depending on the complexity of the request and the number of requests, the controller shall have the right to extend the one-month period by a further two months, informing the data subject before the end of the first month and stating the reasons for such extension.
If the request is made by electronic means, the reply shall also be provided by electronic means, unless this will not be possible (e.g. due to the extremely large volume of information) or if the request specifies another method of reply.
If the circumstances and reasons set out in the legislation for refusing the request are established, a reasoned reply will be given.
VI. Validity and amendments
This Privacy Policy is effective from 1 January 2021. If we change this privacy policy, we will post an updated version on our website www.Hoobrid.com