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Information on the protection of your personal data

Groupe Renault continues to ensure compliance with regulations on protection of personal data (hereinafter the “personal data”) and puts it at the heart of its ethics, as described in its Group Personal Data Protection Policy available at https://group.renault.com/nos-engagements/le-groupe-renault-et-vos-donnees-personnelles/

Indeed, Groupe Renault believes that personal data protection is essential for building a relationship of trust with its customers. As such, it intends to ensure the greatest transparency in the personal data processing that it carries out on the personal data that its customers provide or that it collects through the various contacts its customers may have with it.

The purpose of this privacy notice is to provide you with detailed information about the conditions for the processing of your personal data by Groupe Renault, as well as the rights and options available to you to control your personal data and protect your privacy.

 

In this policy, you will find the following information:

1- Who processes your personal data?

Groupe Renault is an international group:

  • Incorporating the Renault, Dacia, Alpine, Renault Samsung Motors and Lada brands,
  • Composed of different legal entities in France and abroad, responsible in particular for manufacturing, distribution of vehicles and parts and sales of related services such as connected services, maintenance, warranty and financing,
  • And the parent company of which is Renault SAS located in France, at 13/15 quai le Gallo 92100 Boulogne-Billancourt.

Groupe Renault also relies on a network of authorised distributors to sell the vehicles of its brands and related products and services.

Groupe Renault companies and/or its network of distributors may collect and process personal data about you. Their responsibility for processing your personal data varies depending on the Group company or distributor network with which you share your personal data and the role they play in the various services or products provided. For the purposes of this document, “we” or “Renault” refers to Renault SAS and the Renault distributor network.

In general, the following are joint controllers within the meaning of the applicable personal data regulations:

Renault SAS. The contact details for its Data Protection Officer are as follows: Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt.

and the members of its network, the list and contact details of which are available on the website https://www.alpinecars.com/en/our-alpine-centres/.

In certain cases, Renault SAS may also process your personal data as independent data controllers. The contact details for Renault SAS’ Data Protection Officer are as follows: Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt.

 

2- What personal data do we process?

“Personal data” means any information that can be used to identify you either directly (such as your name) or indirectly (e.g. using a unique customer number).

Generally speaking, we undertake to collect only the personal data necessary for each of the purposes for which we process your personal data.

The personal data we collect depends on our interaction with you and may include information about:

  • Your identity and contact details (surname, first name, postal address, email address, telephone, etc.),
  • Data related to your personal and/or professional situation (family situation, socio-professional category, etc.),
  • Your payment and transaction data (payment type, discount granted, etc.),
  • Data relating to our commercial relationship, in particular our interactions and contracts (order history, after-sales operations, service agreements, games, interaction with our call centre, etc.),
  • Your vehicle identification data (brand, model, registration, VIN number, etc.),
  • Your geolocation data (your consent is obtained when required by regulations),
  • Data related to the use of the vehicle (mileage, journey, use of multimedia, etc.) and, where applicable, its battery (charge level, etc.),
  • If you have a connected vehicle, data allowing control of the vehicle and, where applicable, its battery (locking/unlocking, pre-conditioning, battery charge programming, etc.), relating to driving mode (use of controls, acceleration, braking, etc.) or to the provision of connected services or on-board applications,
  • Data needed to carry out loyalty, direct marketing, market research or survey actions (e.g. your vehicle preferences),
  • Data relating to your digital profiles (online accounts),
  • Data concerning the use of our websites and mobile apps, as well as our communications (number of visits, page visited, messages opened, etc.).

As such, the data required to respond to your request or meet the needs of a contract or legal obligation is pointed out in the collection forms (in particular by asterisks). If you do not wish to provide the mandatory data, we may not be able to process your request or provide you with the relevant services. The other information is intended to get to know you better, in particular to send you customised advertisements. This information is therefore optional.

encourage you to keep us regularly informed in writing of any changes to your personal data.

The products and services that we offer are primarily for adults. Therefore, we do not carry out any specific processing on minors.

What is your personal data used for?

We will provide you with explanations relating to the context of collection of your personal data, the purposes for which we process them and the duration for which we retained them.

 

3.1- Context of collection

We collect your personal data in particular when:
– You visit one of our websites, which may use cookies or other tracers,
– You contact us via an online form, email, telephone, live chat, visit to a dealership or by any other means,
– You participate in a game or event, or subscribe to one of our newsletters,
– You purchase a vehicle or a service (maintenance, repair, warranty, connected services),
– You use a connected vehicle,
– You respond to one of our studies or satisfaction surveys,
– You create a user account to access our services from your computer or smartphone,

We may also obtain information about you through other companies in our group or partners, with your consent when required by the regulations.

 

3.2- Objectives of personal data processing

Within the context of our relationship, and in line with the context in which your personal data is collected, we may use your data to:

A – Manage our initial interactions
B – Manage our commercial relationship
C – Conduct studies and analyses
D – Manage our marketing operations

 

3.2.A- Manage our initial interactions

Objectives
Legal basis
Follow up visits to our websites or mobile applications, and manage their operation and security,
This processing is based on your consent to cookies stored/read on your device (see our cookies policy – link to the cookies policy on the website), and on our legitimate interest (to provide you with secure sites and applications)
Requests for information, estimates/quotations, test drives (and possibly recovery of fines related to this test drive), etc.
This processing is justified by the pre-contractual relationship resulting from your request or our legal obligations (cooperation with the authorities for the recovery of fines)
Navigation and interaction with our Facebook fan page
This processing is justified by the contractual relationship you have as a Facebook user. In this context, Renault XX and Facebook are joint data controllers.

We draw your attention to the fact that Facebook carries out activity and statistics reporting in anonymised form from visits to the “fan page” for the purposes of managing the promotion of Renault’s activity, and can also use them to improve the Facebook advertising system. You can get more information about how Facebook processes personal data by consulting its privacy policy available at: https://www.facebook.com/about/privacy

 

3.2.B- Manage our commercial relationship

Objectives
Legal basis
Management of your vehicle order (including tracking from manufacture to delivery), registration request, documents order related to your vehicle, contracts (maintenance, extended warranty, connected services), repairs, warranty (including your requests for support), roadside assistance, etc.
This processing is justified by the fulfilment of the agreement you have entered into with us.
Management of your user accounts and means of authentication
This processing is justified by the fulfilment of the agreement you have entered into with us.
Management of your participation to forums, communities
This processing is based on your consent.
Management of your complaints
This processing is based on our legitimate interests (prevention of legal action)
Responding to your possible requests to exercise rights in relation to your personal data (see the section on "your rights")
This processing is based on our legal obligations and may involve checking your identity
Management of our satisfaction surveys, management and response to your opinions, in order to improve customer satisfaction and our products and services,
This processing is based on our legitimate interests (to improve our products and services)
Management of our consolidated prospects/customers database
This processing is based on our legitimate interests (to have an up-to-date and consolidated overview of the data)
Management of your vehicle relationship, in particular the various operations carried out on your vehicle,
This processing is based on our legitimate interests (following the quality of our products)
A vehicle recall due to a quality problem
This processing is based on our legal obligations (regulations on defective products) and on our legitimate interests (to ensure the quality of our products)

When you are in contact with our call centres, our objective is to best meet your demands. To improve the quality of our services and to train and assess our employees, your calls may be recorded. However, you may oppose this at any time and without reason.

 

3.2.C- Conduct studies and analyses

Studies and analyses are conducted to measure our performance, assess the quality of our products and services and the level of customer satisfaction, and to continuously improve them.

Objectives
Legal basis
Invite you to respond to studies within the context of development of new products and services and to measure our brand image,
This processing is based on your consent
Produce analyses to measure our commercial performance, including the effectiveness of our marketing operations,
This processing is based on our legitimate interests (to measure the performance of our activity)
Research and development of our products and services
This processing is based on our legitimate interests (to improve our products and services)
Ensure the quality of our vehicles, parts, and services, including incident and durability studies,
This processing is based on our legitimate interests (to improve our products and services)
Conduct analyses to improve customer satisfaction
This processing is based on our legitimate interests (to improve our products and services)

 

3.2.D- Manage our marketing operations

Objectives
Legal basis
Send advertising campaigns (digital or otherwise) and newsletters,
This processing is based on your consent and/or our legitimate interests (to provide you with relevant information)
Games and contests, events and sponsorship,
This processing is based on the contract (acceptance of the rules)
Online targeted advertising, customisation of content,
This processing is based on your consent to cookies stored/read on your device (see our cookies policy)
Advanced analysis for marketing customisation (profiling) and improvement of customer and market knowledge
This processing is based on our legitimate interests (to get to know the behaviour of our customers and prospects better and/or to provide you with relevant content)

We analyse the personal data of our customers and prospects, both the data they have provided to us directly (including data related to browsing on our websites and the use of our mobile applications, subject to consent) and data from third parties (subject to consent where necessary), to create algorithms that enable us to assess and/or predict their potential interests and preferences for our products and services (using scores and segmentation).

These analyses are intended to provide you with personalised content, such as specific offers by email, content on our websites or third-party websites, etc. For example, processing of this data may lead us to send you offers relating to the car segment likely to be of interest to you. This also enables us to not send you advertising offers if we understand that they will not match your interests.

The use of such tools is defined as profiling by the regulations. We believe it is in our legitimate interests to understand the preferences of our customers and prospects in order to provide them with content that meets their needs or desires. We have weighed up the respective interests and have put in place measures to ensure that your fundamental rights and freedoms are not breached.

More information is available on this point on request. If you do not wish us to send you offers based on profiling, you can object to them by referring to the “how to exercise your rights” section.

 

3.3- The length of time for which we keep your data

In accordance with the regulations, we are committed to keeping your personal data only for the time necessary to achieve the objective pursued, to meet your needs, or to meet our legal obligations.

In determining this time, we take into account, in particular, the following:

  • The length of your contract,
  • The time required to process your request or complaint,
  • The length of time your user account has been open, unless it has been inactive for 3 years,
  • Your interest in our brands,
  • The need to keep a record of your interactions with us, to effectively manage our business relationship. This period will vary depending, in particular, on whether you have bought a vehicle or a service such as repair, or whether you have only interacted with us without entering into contracts with us,
  • Our legal or regulatory obligations (this is particularly the case for the technical data of our vehicles).

When we no longer need to use your personal data, it is deleted from our systems and records or made anonymous so that we can no longer identify you. However, it may be necessary to archive some of your personal data in order to be able to respond to any legal proceedings, throughout the statute of limitations provided for in the applicable legislation.

 

4- Who has access to your personal data?

Within Groupe Renault and its network members, we ensure that only those people who are duly authorised for their functions and tasks to process your personal data are allowed access.

We may share your personal data with Renault SAS. We may also share your personal data with other companies in Groupe Renault such as Renault MAI, in charge of mobility activities (such as car sharing), or subsidiaries offering financial services, such as RCI Banque SA, subject to your consent when required by the regulations. These entities may act as data controller, in accordance with their personal data protection policy, or as processor, to perform tasks according to the instructions we give them.

In order to process all or part of your personal data, we call upon trusted third-party providers acting as processors in accordance with our instructions and solely on our behalf, including:

  • Hosting, operation or maintenance of our databases, websites and mobile applications,
  • Provision of authentication services,
  • Customer relations management (call centres, communication tools, etc.)
  • Provision of services relating to our marketing, including the sending of commercial offers,
  • Organisation of competitions and events,
  • Performance of studies and surveys.

For all of this data sharing, we ensure that we only work with trusted companies and secure these relationships (contracts, audits, guarantees and security tests, etc.).

In some cases, we may share some of your personal data with partners, who will use it for their own purposes. In such a case, these partners shall act as data controllers and their personal data processing policy shall apply to the data shared. We make sure to ask you for your consent to this sharing when required by the regulations, or at least to enable you to object.

We may also offer you the opportunity to use your social network login data. Please be aware that, in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform. Please note that these social networks apply their own privacy policies.

Finally, we may be required to communicate your personal data to third parties in order to comply with a legal obligation (e.g. to recover a traffic fine following a test drive) or an administrative or legal decision.

 

5- What are your rights?

5.1- Your rights

You have several rights under personal data protection regulations:

A right to object to the processing of your personal data, provided you have grounds connected with your particular situation, and the right to request the limitation of your personal data processing, in some cases as provided for in regulations.

A right to object to any commercial solicitation: you can ask at any time not to receive our communications related to our offers, news and events. This right may, in particular, be exercised via the unsubscribe link in each marketing email. You can also object to profiling.

A right to withdraw your consent at any time, for the purposes for which we obtained your consent.

A right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. This policy is an example of this.

A right of access to your personal data: you have the right to obtain information concerning the processing of your personal data (including the data that is used, for what purposes, etc.) and a copy thereof.

A right of rectification: you have the right to correct your data if it is inaccurate or incomplete, despite our efforts to keep it up to date, enabling us to comply with our obligation to have up-to-date data about you.

A right to the portability of your data, i.e., under certain conditions, the right to receive the personal data you have provided to us, in a structured, commonly used computerised format, and for it to be transmitted to a third party if technically possible.

A right to erasure (or right to be forgotten): you have the right to have your data erased or deleted. This right may be limited in light of our contractual or legal obligations (contract in progress) (prevention of legal action in particular).

A right to define either general or specific guidelines regarding certain types of processing, with respect to the retention, deletion and communication of your personal data in the event of your death. You may change or delete these guidelines at any time. You may share these special guidelines with us by writing to the address below.

Finally, you have the right to lodge a complaint with Information Commissioner’s Office about the processing of your personal data. We encourage you to contact us prior to any claim, so that we may attempt to resolve your problem together.

 

5.2- How do I exercise them?

You can update your contact details and manage your marketing preferences directly in your user account (MyRenault, MyDacia, etc.).

To exercise any of your rights, you can send us your request at any time via [the form https://www.alpinecars.com/en/contact/ or by post to Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt, France.
We may request certain information or documents (identity document, vehicle registration document) when we fail to identify you or to identify your vehicle data.

You have the right to register free of charge on the Bloctel opt-out list, managed by the company Opposetel, to no longer receive unsolicited sales or marketing calls. However, registration on this list does not prohibit us from contacting you for marketing purposes during the term of your agreement with us, unless you have specifically exercised your right to object to receiving commercial offers from us.

 

6- How is your personal data kept secure?

Your personal data is stored on secure servers. We put in place, and require from our processors and partners, appropriate data security and data protection measures in line with the latest technologies.

When personal data processing involves transferring data, we ensure that this transfer is carried out under appropriate conditions that ensure an adequate level of protection, security and confidentiality.

When a digital account is created, entering a password that respects our security standards is mandatory and is part of our privacy policy. It is your responsibility to keep it secret.

Whenever possible, your data is processed in the European Economic Area (EEA). However, as some of our service providers or their processors are located in countries outside of the EEA, your personal data may be processed in those countries. Some of these countries may have different personal data regulations from those of the European Union. In such a case, (i) we pay particular attention to ensuring that this transfer is carried out in accordance with the applicable regulations and (ii) we put in place safeguards ensuring an adequate level of protection of your privacy and fundamental rights (in particular by using the European Commission’s standard contractual clauses). Upon simple request sent to the address indicated in the “What are your rights?” section, we can provide you with more information on such transfers (in particular the European Commission’s standard contractual clauses).

 

7- Modification of information

We may change this information from time to time. We will inform you and/or seek your consent whenever necessary or required. We therefore recommend that you consult this policy each time you visit our website in order to review the latest version.

 

Version 3 updated on 10 november 2020

This new version is a major overhaul of the previous version. It is more accessible and more comprehensive. Here you can find all the terms and conditions governing use of your personal data (in particular the complete list of our purposes). The processing of your personal data for connected services and on-board applications is now included in this policy. We provide you with new information about profiling. This version also provides more transparency about the recipients of your personal data, within or outside our group.