Privacy Policy BOCA AUTOTRADE S.R.L

INTRODUCTION

The present Privacy Policy describes the your data categories that we process, the way and scope in which we collect them, in which situations we transfer and/or reveal data with personal character and the diverse rights and options you have towards this end. In the same time, our Privacy Policy details the way we process data with personal character in handling our relation with clients and more often to keep you up to date with the most recent evolution and events in your area of interest.

We ask that you consult our Terms and Conditions available in our website www.autoboca.ro and the Cookie Policy, where you will find in detail the use of cookies and other web beacons/localization through our website.

WHO PROCESSES YOUR DATA WITH PERSONAL CHARACTER

BOCA AUTOTRADE S.R.L, with social office in Radauti, Street Mihai Viteazul, Bl. 16A, Sc. A, Floor 1, Apartment 1, Suceava County , with Registration Number at the Commerce Registry J33/1119/2008, CUI 24188140, email rezervari@autoboca.ro (Autoboca) is the operator of your data with personal character.

Data categories we process

Data with personal character that we process may include:

Contact information, such as your name, post, home address, work address, phone number, mobile number, fax number and email address; Additional commercial information mandatory processed through a contract with Autoboca, payment made and details regarding bank account; Autoboca undergoes, during its activity, a surveillance of the cars through a global positioning system (GPS). The GPS is used in the car, in the form of a device with the same name, connected to the satellite, which gives Autoboca the possibility to verify the car’s location. The information collected by Autoboca through the GPS use are stored on a server administrated by the suppliers of such services with whom Autoboca collaborates. In the event that you want to participate to the recruitment process for a job within our organisation, your personal data given by you will be used by us to identify the right candidates. The data won’t be communicated to third parties and will be exclusively used for the purpose mentioned, and in strict conditions of security and confidentiality.

How Autoboca collects your data with personal character

We can collect data with personal character regarding you, in some circumstances that may include:

When you ask to use our services; When you benefit from our services, through the use of rented car; When you navigate, ask for information or interact on our website; When you with to subscribe to receive information and offers from us; When your employer undergoes or offers to undergo services for us; When you wish to send us data (CVs) in order to occupy a position in our organisation; In certain circumstances, we collect data with personal character regarding you from a third party. For example; we may collect data with personal character from your employer.

Legal grounds to process data with personal character

Every operation that represents a process, according to the law, (such as but not exclusively limited to collecting, storing, recording, structuring, adapting or modifying, extracting, consulting, utilising, revealing through transmission or destruction) of your data with personal character can be done on the basis of one of the legal grounds presented below:

Processing is necessary during the closing and/or executing a contract with you or your employer; Processing is necessary when it has to respect a legal obligation;

Processing is necessary in the scope of Autoboca legitimate interests, with the exception of cases in which your fundamental interests, liberties and rights prevail these interests. More clearly, the data is processed in the basis of Autoboca legitimate interests to protect its goods, respectively to improve its services and to keep its clients informed about certain events and promotions, to keep its clients close and reward their loyalty.

Processing is done in the grounds of your consent, explicitly and preliminary given; In any moment, you have the right to withdraw your consent. In order to withdraw your consent for any processing on which you preliminary consented, please feel free to communicate your desire through an email sent at the address privacy@autoboca.ro or to communicate it through a written solicitation using Autoboca address. In any case, the consent can be withdrawn in the same way it was given.

You can choose to withdraw your consent regarding marketing materials at any time, by simply accessing the link “unsubscribe” present at the bottom of each newsletter.

In the cases in which you withdraw your consent, Autoboca won’t allow the process of your data and will take the appropriate measures to delete any recordings of your data with personal character. Still, in the event in which the process is strictly necessary in order to perform Autoboca services, and the processing can be based on other legal grounds as presented in the legal applicable dispositions, Autoboca will proceed to the respective processing and will inform you accordingly.

We process your data with personal character in the following purposes

We can use your personal character only in the following purposes:

Undergoing the services requested of Autoboca; Resolving any demands and/or complaints regarding certain services provided; Protecting goods pertaining to Autoboca and the proper administration of Autoboca goods, especially when it comes to control of car location in order to prevent theft situations; Respecting our legal obligations (such as storing evidences); Analysing and improving services and communications to you; Polls among clients and market analysis; Protecting the security and handling access to our offices, IT systems and communication, online platforms, websites and other systems; In the purpose of monitoring and evaluating our policies and standards; If you applied for the occupation of a position in our company, the given data are necessary to identify if your professional experience is right for the position you applied; In any afferent purpose and/or auxiliary of any of the ones presented above or in any purpose for which your data with personal character were given to us; In the case in which you gave your consent to process your data with personal character to the following purposes:

Communicating with you through the consented channels in order to keep you up to date Autoboca news, announcements, information regarding services and Autoboca products, and also events and Autoboca projects (direct marketing); We shall not use your data with personal character in take automated decisions that might affect or to create other profiles than the ones described above.

Sharing your data with personal character

We can share your data with personal character in the following circumstances:

We can share your data with personal character with justice departments, law authorities, regulation authorities or lawyers or other persons if it is proven necessary, in a just manner to establish, exercise or defend a right in court or natural right, or in the purpose of a trial to alternatively resolve, confidentially of disputes;

We can use your data with personal character aggregate and statistics in order to monitor the use of Autoboca website.

Furthermore, we can share your data with personal character with our authorized persons – mainly service providers within and outside Autoboca (such as insurance societies,…) in order to process data with personal character in the scopes mentioned above, in our name and only in accordance with our instructions. Autoboca will retain control over your data with personal character and will use the appropriate protection measures, in accordance with law in use, to ensure the integrity and security of your data during the request of the service providers.

Otherwise, we shall reveal your data with personal character only when you instruct so or you offer permission, when it is imposed upon us by the law in use or regulations or requests from judiciary or official authorities or as it is customary during investigation of fraudulent or illegal activities.

If you decide you pay by credit card, by clicking on the Reserve+ button from the Confirm reservation page, you understand and agree that: You will leave Autoboca interface and you will be redirected in the payment processing interface with PayU card ( www.payu.ro); Any data you introduce in the website/interface www.payu.ro will be subjected to the Privacy Policy of PayU; The data introduced in the site/interface www.payu.ro will be saved by PayU within the European Community; PayU will be responsible for processing the data you introduce in the website/interface www.payu.ro.

DATA WITH PERSONAL CHARACTER THAT YOU OFFER US REGARDING OTHER PERSONS

In the event you provide us with data with personal character regarding another person (such as one of the administrators or employees, or a person with whom you have professional relations), you must be sure that you have the right to reveal such data with personal character and that, without taking other measures, we can collect, use or reveal such data with personal character, as described in the present Privacy Policy.

In addition, you must be sure that the person in question is aware of the various aspects present in this Privacy Policy, as they describe the person in question, including our identity, the way we can be contacted, the purposes we collect, our practices of reveal of data with personal character, the right of the individual to obtain access to the respective data and to hand in complaints regarding the management of data with personal character and the consequences of not offering data with personal character (such as our impossibility to offer services).

KEEPING DATA WITH PERSONAL CHARACTER

Data with personal character can be kept in our technological systems of data with personal character, those of our contractors or in printed form. We have adopted all the measures that are imposed, regarding persons that get in contact with the data, the spaces in which the data are processed and also the technical used in regards to the data processing, to make sure that the data is safely processed, while ensuring their confidentiality and preventing unauthorized access or loss of data.

UPDATING DATA WITH PERSONAL CHARACTER

In the event in which the data with personal character that you provided suffered modifications, for example: if you changed your surname, name, email address or if you want to cancel any type of demand from Autoboca, or if you want to let us know that we have incorrect data with personal character regarding you, please communicate with us by sending an email at privacy@autoboca.ro.

HOW LONG DO WE KEEP YOUR DATA WITH PERSONAL CHARACTER

Autoboca has implemented technical and organisational measures to organize the process and criteria foreseen for the deletion and elimination of data with personal character.

Data with personal character will be deleted or eliminated when they are not necessary for the purposes they were received or if you withdraw your consent (if the need be) and Autoboca does not have the legal obligation to continue storing the respective data. Still, we shall keep your data with personal character when they are needed to exercise or defend by Autoboca of one of your rights or another person in court, until the relevant retention period is over or until the resolve of the respective actions in court.

With the exception of an explicit solicitation to store your data with personal character on a longer period of time or in the case in which the data are necessary to defend a specific right in court without the retention period, the data with personal character will be deleted in a time frame of 5 years from the date they were collected.

YOUR RIGHTS REGARDING PROCESSING DATA WITH PERSONAL CHARACTER

Under the reserve of certain legal conditions, you have the following rights regarding processing your data with personal character:

1. The right to ask Autoboca access to the data collected. You have the right to obtain from Autoboca a confirmation that the data with personal character concerning you are processed or not and, if they are, you have access to the respective data and to the following information: type of data we process, to what end, if the data was revealed to third parties and to whom, and the storing period of the data. We shall inform you again to the rights you have regarding the personal data, detailed rights in this notice. You have the right to receive free a copy of the data with personal character which make the object of the process. For any additional copies we reserve the right to perceive a tax. You ask for the information in electronic format, situation in which the data will be delivered in an electronic form currently used by us, with the exception of the case in which you ask for them in another format.

2. The right to ask Autoboca to rectify data. You have the right to obtain, without unjustified delays the rectification of inexact data with personal character that concern you and/or obtain the completion of data with personal character that are incomplete, by providing an additional declaration.

3. The right to ask Autoboca to delete the data. You have the right to ask Autoboca to delete the personal data that concern you, without any unjustifiable delays, and Autoboca has the obligation of deleting the data with personal character that concern you, in the case one of the following reasons is applied:

Data with personal character are no longer necessary to fulfil the scopes they were collected or processed; You exercise the right to oppose, in the conditions described at the right to oppose and there are no legitimate reasons to prevail the process; You exercise the right to oppose in regards to the use of your data in the scope of direct marketing; Data with personal character were illegally processed; Data with personal character must be deleted to respect a legal obligation of the operator in the grounds of European or national legislation;

4. The right to ask Autoboca to restrict the processing of data. You have the right to obtain from our part the restriction of processing data with personal character, in the following conditions:

If you contest the correctness of the data processed, for a period that will allow us to verify the exactness of the data; If the processing is illegal, and you did not exercised your right of deletion, you have the right to ask for a processing restriction; If the operator no longer needs your personal data in the scope of processing, but you ask for them as evidence, exercising or defending a right in court; In the event in which you oppose to the processing on the period of verification if the legitimate rights of the operator prevail those of the person in question. In the case in which you obtained the restriction of data processing, we shall inform before the restriction is lifted.

5. The right to oppose at any moment. You have the right related to the special situation in which you are in, to oppose the processing of your personal data. We will no longer process your data with the exception of the case in which we have legitimate and imperious reasons, which we can prove, that justify the processing and prevail your rights and liberties or if the scope of the processing is ascertainment or defending a right in instance.

Furthermore, you have the right to oppose the data processing at any time, when the scope of the processing is marketing direct, including the creation of profiles when it is linked to marketing direct.

When you oppose the processing, in the conditions presented above, the data with personal character are no longer processed.

The rights mentioned above can be exercised through a written request, addressed to Autoboca, at the following address privacy@autoboca.ro. It is possible that we ask to prove your identify by communicating a copy-proof of a viable method of identification in order to conform with the security obligations we have and to prevent the unauthorized reveal of the data.

We shall take into consideration any solicitation or complaint that we receive and we will respond in a timely fashion.

If you are not pleased with our answer, you have the right to send a complaint to the National Authority of Data with personal character processing.

Updating the privacy policy

The present Privacy Policy was updated in the month of May 2018. We reserve the right to periodically update and modify the present Privacy Policy, in order to reflect any modification in the way we process your data with personal character or any modifications of legal requests. In the case of such a modification, we will display on our website the modified version of the Privacy Policy and/or we shall offer it in another way.

CONTACT

If you want to contact us with questions regarding the present privacy policy, as well as processing data, please feel free to send us an email at the address privacy@autoboca.ro or to send a written request at the following address: Macelariu Horia Street, number 1, Bl. 13, Ground floor, Bucharest, Postal Code 013902.