PERSONAL DATA

How we collect your personal data?

Spectrum Automobile processes your personal data, among others, on the following occasions:

• If you contact us directly, for example via the website, to request information about our products and services.
• If you purchase a product or service directly from us.
• If you respond to our direct marketing campaigns, e.g. filling in a response card or entering data online on our website.
• If your personal data is transferred from our group companies or other third parties.
• If other business partners, as permitted, transfer your personal data to us.
• If we have acquired your personal data from other sources (eg commercial address brokers)

If you provide information on behalf of a third party, you must ensure that they have received this privacy policy before doing so.

If you are under 16, please do not provide us with any information unless you have your parent or guardian permission to do so.

What information we may collect about you

The following types of information about you may be collected:

• Contact details: name, title, initials, address, telephone numbers, e-mail address, fax number
• Personal data: date of birth, family status, family members, driving license (type), profession, test drive, hobbies, preferred payment method, preferred contact channel, company name, VIN.
• Interests: information about your interests, including the type of vehicle you are interested in
• Use of our website and information communicated: how you use our website and whether you open or transmit our communications, including information collected through cookies and other technologies.
• Sales and service information: information related to purchases, including customer ID, contract number and financing option information, support and service, including complaints and complaints.
• Customer history information: Customer satisfaction rates (and additional information from the self-service platform), offers received, car purchase data including model, configuration, purchase date, registration date, registration number, order date, list pricing, warranty information, residual value, optional insurance information (e.g. household vehicles, use of mobility services) products, data collected during showroom visits (e.g. inquiries, consultation information, responsible sales consultant , service history), campaign history / campaign responses, complaint history, service history.
• Vehicle configuration details: information about your vehicle current features and settings (identified by your vehicle registration number).

How your data may be used

The GDPR (EU Regulation No. 679 of April 27, 2016) requires that the use of personal data be justified by legal "grounds" and we are required to establish these grounds for each use through this policy. Here are the grounds we use to justify each use of your information for each use:

Customer Relations and Marketing –

to answer your questions and send you news and offers.

Spectrum Automobile collects contact data, personal details and interests, customer history information, website and communications usage information and may use sales information, vehicle configuration details and vehicle technical information to determine what news and offers are of interest to you and to contact you about these offers in accordance with your marketing preferences. Spectrum Automobile can communicate this information to the companies within the group as well as to some partners in order to follow your requests and to offer you more specific offers.

Reason for use: Consent, legitimate interest.

Legitimate interest: This processing is based on the legitimate interest of Spectrum Automobile in order to promote and provide information about its products and services. The fundamental rights and freedoms of customers and potential customers have been assessed in relation to our interest in processing personal data for the identified purpose.

Choice: Marketing consent can be withdrawn at any time with effect for the future. The customer can also object to processing for direct marketing purposes.

Sales –

to process the sale, set up and service your vehicle.

Spectrum Automobile will obtain Contact Details, Vehicle Configuration Details, Vehicle Technical Information and Sales and Service Information and Customer History Information when you purchase a vehicle from or with it as part of the sale, including inquiries warranty and regular checks, and will use them to provide the services you request and to notify you of matters relating to your vehicle.

The provision of personal data for the purpose of Vehicle Sales is a contractual requirement and the refusal to provide it will affect the correct performance of the contract or even make it impossible.

Justification of use: Execution of the contract; legitimate interests.

Legitimate interest: This processing is based on the Spectrum Automobile group legitimate interest in maintaining the highest standards of sales offered. The fundamental rights and freedoms of customers have been assessed against our interest in processing customer data for the identified purpose.

Choice: The customer can object to the processing of his personal data for reasons related to his particular situation at any time.

Compliance with mandatory requests to provide your information –

to comply with our legal obligations to law enforcement, regulatory authorities and the judicial service.

The Spectrum Automobile Group is subject to the laws of Romania and must comply with those laws. This includes providing your information to law enforcement agencies, regulatory authorities and courts and third parties in connection with proceedings or investigations anywhere in the world when required to do so. If permitted, we will send you such a request or inform you before responding, unless doing so would prejudice the prevention or detection of a crime.

Providing personal data for the purpose of complying with mandatory requests for your information is a regulatory requirement that depends on the request in question.

Justification of use: Legal obligation; establishing, exercising or defending legal claims.
Choice: None

Transfer to third parties

Personal data may be transferred to third parties, ensuring that there is a legal basis for the transfer.

• Your personal data may be transferred to the following entities:
• The companies from the Spectrum Automobile group (Spectrum Business Group SRL)
• Contractual partners
• Companies that provide services to Spectrum Automobile, such as IT maintenance.
• IT maintenance, IT hosting, customer interaction center provider.

Although we cannot guarantee that the transmission of data over the Internet or on the Site is free from cyber attacks, we, our subcontractors and our business partners strive to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements.

All your information is stored on the secure servers (or in secure physical format) of our subcontractors or business partners and is accessed and used in accordance with our security policies and standards (or equivalent standards of our subcontractors or business partners).

How do we keep your information safe?

Within the Spectrum Automobile group, personal data is considered confidential information and is protected by appropriate organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction.

Although we cannot guarantee that the transmission of data over the Internet or on websites is free from the risks of cyber attacks, we, our subcontractors and our business partners strive to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. We use, among others, measures such as:

• Strict control of personal access to your data based on the "need to know" principle and only for the communicated purpose
• storing strictly confidential data - under the control of specific security measures.
• use of computer security systems to prevent unauthorized access, e.g. by hackers.
• permanent monitoring of access to IT systems to detect and stop improper use of personal data.

If we have provided you with (or you have chosen) a password that enables you to access certain parts of our website or any other portal, application or service we operate, you are responsible for keeping this password confidential and complying with any other security procedure we notify you of. We request that you do not share such password with anyone.

How long do we keep your information?

Spectrum Automobile will only retain your information for as long as is necessary for the purpose for which it was collected and for any other permitted related purposes (for example, where relevant, for the defense of a claim against us). So if the information is used for two purposes, we will retain it until the purpose with the longer period expires, but it will no longer be used for the purpose with the shorter period once that period has expired.

Retention periods are based on legal requirements and business needs, and your personal data that is no longer necessary for our purposes is destroyed or securely deleted.

Use for customer support and marketing: In relation to your information used for customer support and marketing purposes, we may retain the information for this purpose until the date we last obtained your consent to send you marketing messages or the date on when was the last time you responded to a marketing communication from us (other than opting out of receiving further communications).

Use to perform a contract regarding their sale or financing: In relation to information used to fulfill any contractual obligation, we may retain this data for as long as the contract remains in force plus 10 years after the last contact to answer any questions or to resolve any claims arising after the termination of the contract.

In the case of other categories of personal data that we collect (for example video recordings from the showroom or from the premises belonging to our group) please note that when establishing the data retention periods we are obliged to take into account the specific legal provisions.

If there are possible claims: in relation to any information that we reasonably believe will be necessary to defend, pursue or make claims against the customer, us or a third party, we may retain that data for as long as that claim it could be within the legal term to be formulated.

Your rights regarding the protection of personal data

Each data subject has the rights below under applicable law. Any request you submit to us will be dealt with immediately by a Spectrum Automobile data protection officer and will be answered without undue delay within one month. In special situations or when numerous requests are received, this period can be extended by another two months, a period of which you will be informed.

As a result, you have the right:
– ask us for further details about how we use your information;
– to obtain access to your personal data and a copy of the information you have provided to us;
– to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format and – if technically feasible – to transmit this data to another controller without hindrance, if the processing is based on your consent or the execution of the contract and if it is done by automated means;
– to request the rectification, updating or deletion, in whole or in part, of your data;
– where the processing is based on consent and in relation to any direct marketing, withdraw your consent with effect for the future so that we stop that processing;
– to object to any processing unless our reasons for continuing such processing outweigh any prejudice to your data protection rights;
– ask us to restrict the way we process the information.

The exercise of these rights is subject to certain exceptions to protect the public interest (for example, preventing or detecting crime), our interests (for example, maintaining legal privilege), or the rights and freedoms of others. If you exercise any of these rights, we will consider your right to such a request and respond without undue delay, but no later than one month. In complex cases or when receiving numerous requests, this period can be extended by another two months, a period of which you will be informed.

To exercise these rights, you can communicate your wish to contact@spectrumauto.ro or to the phone number +40 743 77 55 22 from M-F between 9.00-18.00.

Scope and modification of the policy

This data protection policy applies to all personal data collected and to the processing of this data within the processes of the Spectrum Automobile group. The data protection policy extends to all actions related to personal data belonging to both customers and business partners as well as our employees.

The policy is reviewed annually and the latest version will be immediately available on the website to our customers and business partners. Spectrum Automobile has the right to modify this policy whenever necessary to comply with applicable legal requirements and therefore please re-read this policy from time to time.