Privacy policy

NOTICE ON THE PROCESSING OF PERSONAL DATA

Dear,

DELTA AUTOMOTO d.o.o. Beograd, Omladinskih brigada 33a, Belgrade, registration number: 20236507 (hereinafter: “the Company” or “We”), respects and protects the privacy of every person (natural persons – client, potential client or other person – hereinafter collectively referred to as: “Client” or “You”) whose personal data it collects (hereinafter: “Personal Data”). The collection and storage of Personal Data is carried out in accordance with the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia” no. 87/2018) (hereinafter: “the Law”) as well as with the EU General Data Protection Regulation (EU 2016/679) (hereinafter: “GDPR”), where applicable.

In the case of processing the Personal Data of Clients who are citizens of one of the member states of the European Union, We will also apply the provisions of the GDPR, to the extent applicable.

We value You and recognize that privacy is important to You.

In order to protect the privacy of every Client whose Personal Data we collect, We have published this Privacy Policy, which defines what Personal Data we collect, in what way, for what purpose we process it, how we protect it, how long we keep it, as well as what your rights are in relation to Personal Data.

Namely, we have developed this Privacy Policy in order to present to You our practice regarding the collection of Personal Data that we collect from You or about You on this website, through written or oral communication with us, when you visit one of our facilities or from other sources.

In any case, feel free to contact the personal data protection officer at the email address: zastitapodataka@deltaautomoto.rs.

Basic terms and personal data processed by the Company

“Personal Data” is any data relating to a natural person whose identity is determined or determinable, directly or indirectly, in particular on the basis of an identity marker;

“Processing of Personal Data” is any action or set of actions performed in an automated or non-automated manner with personal data or sets of data, such as collection, recording, sorting, grouping, i.e. structuring, storing, adapting or altering, disclosure, access, use, disclosure by transmission, i.e. delivery, duplication, dissemination or otherwise making available, comparison, restriction, erasure or destruction;

“Sensitive Data” refers to data relating to racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, genetic information, criminal record and biometric data used for the purpose of unique identification.

We do not collect Your sensitive data, unless You make it available to us voluntarily or unless we are obliged to do so by applicable regulations. We may process Your health data that You have provided to us in order to meet Your special needs (for example, in the case of disability).

“Personal Data of Children” refers to persons under 18 years of age.

We do not collect Personal Data of children. As a parent or legal guardian, you should not allow your children to make their Personal Data available without your permission.

Personal Data that the Company collects and processes about You includes:

  • First and last name;
  • Gender;
  • Personal identification number (JMBG);
  • Date and place of birth;
  • E-mail address;
  • Landline phone number;
  • Mobile phone number;
  • Driver’s license number;
  • ID card number/passport number;
  • Residential address (street and number, postal code and place/city);
  • Motor vehicle chassis number;
  • Motor vehicle engine number;
  • Vehicle registration plates;
  • Service booklet;
  • Number of the concluded contract;
  • Marital status;
  • Company in which you are employed.

Method of collecting Personal Data

Personal Data is collected directly from You, as the person whose data is being processed, or from other persons.

Direct collection of Personal Data from Clients whose data is processed

When purchasing a motor vehicle

When concluding a motor vehicle sales contract (including sending an offer to purchase a motor vehicle), for the purposes of concluding and performing the contract, fulfilling the Company’s legal obligations and protecting Your vital interests, You are obliged to provide us with the following Personal Data: first and last name, gender, residential address (street and number, postal code and place), mobile phone number, landline phone number, JMBG, ID card number/passport number and possibly other Personal Data of which you will be informed in advance.

If you do not provide us with the above Personal Data, We will not be able to conclude and perform the motor vehicle sales contract, nor will we be able to respond to Your request.

The purpose for which we process the above Personal Data is the conclusion and performance of the vehicle sales contract, compliance with legal obligations, protection of Your vital interests and the consideration of various complaints/requests related to the Company’s products and services.

The above Personal Data is stored in the Company’s database permanently.

When taking over a motor vehicle for a test drive, or when taking over a replacement vehicle

Before we enable You to try our motor vehicles on a test drive, it is necessary to conclude a motor vehicle use agreement, and for the purposes of concluding and performing the motor vehicle use agreement (test drive, replacement vehicle) it is necessary that you provide us with the following Personal Data: first and last name, gender, residential address (street and number, postal code and place), JMBG, ID card number/passport number, date and place of birth, mobile phone number and driver’s license number.

If you do not provide us with the above Personal Data, We will not be able to conclude and perform the motor vehicle use agreement, nor will we be able to respond to Your request.

The purpose of data collection is the conclusion and performance of the vehicle use agreement.

The above Personal Data is stored in the Company’s database permanently.

When visiting a car showroom

When You visit our car showroom, we collect the following Personal Data from You: first and last name, gender, mobile phone number, landline phone number and email address, in order to inform You in a timely manner about promotions and benefits of motor vehicle sales by the Company that we believe may be of interest to You or in which You have expressed interest, i.e. for the purpose of preparing a special offer for the sale of a motor vehicle, inviting You to events, sending newsletters, and communication.

The purpose of processing the above personal data is notification and information for the purposes of the Company’s promotion and marketing.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

During the Company’s marketing and other promotional campaigns (including fairs)

During the promotion of our products, we may collect the following Personal Data from You: first and last name, gender, mobile phone number, landline phone number and email address, in order to inform You about all the news and benefits that the Company has prepared for You.

The purpose of processing the above Personal Data is promotion, marketing of the Company, as well as surveying Clients who purchase products and services.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

When servicing a car

In order to provide You with the service of servicing Your motor vehicle, to prepare an offer related to vehicle maintenance and/or the procurement of spare parts, and to send reminders for a scheduled service and reminders about the annual service of the motor vehicle, We collect the following Personal Data from You: first and last name, gender, residential address, JMBG, ID card number/passport number, date of birth, mobile phone number, landline phone number, service booklet, number of the concluded contract, motor vehicle engine number, motor vehicle chassis number and registration plate number.

The purpose of processing the above Personal Data is the provision of motor vehicle servicing (including the procurement of spare parts and responding to inquiries regarding the fee for servicing), consideration of various complaints/requests related to the Company’s products and services, and sending notifications about the annual service, including reminders for a scheduled service.

The above Personal Data is stored in the Company’s database permanently.

When subscribing to the newsletter

When subscribing to the newsletter, You give the Company consent to collect the following Personal Data: email address.

The purpose of processing the above Personal Data is sending notifications about special and personalized offers, news and events organized by the Company, internet promotion, and participation in prize games.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

When You contact our employees

When You contact our employees (by phone, through our website or through social networks) in order to get answers to various inquiries regarding our products and services, You give the Company consent to collect the following Personal Data: first and last name, gender, email address and mobile phone number/landline phone number. The purpose of processing the above Personal Data is to establish communication with You in order to answer Your inquiries or to clarify Your request. Providing the above Personal Data is a necessary condition for establishing communication between You and the Company. Otherwise, we will not be able to respond to Your inquiry.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

When You contact our employees (by phone, through our website or through social networks) in order to schedule a service for Your vehicle and determine the fee for service, and to send reminders for a scheduled service, You give the Company consent to collect the following personal data: first and last name, gender, email address, mobile phone number/landline phone number, vehicle chassis number and vehicle engine number. The purpose of processing the above Personal Data is scheduling an appointment for the service of Your vehicle and providing additional information regarding the provision of vehicle servicing, including sending reminders for a scheduled motor vehicle service.

Providing the above Personal Data is a necessary condition for scheduling an appointment for the service of Your vehicle. Otherwise, we will not be able to check for an available appointment and schedule a service for Your vehicle.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

When You contact our employees (by phone, through our website or through social networks) in order to schedule a test drive, You give the Company consent to collect the following personal data: first and last name, gender, email address and mobile phone number/landline phone number.

The purpose of processing the above Personal Data is scheduling an appointment for a test drive and informing You about it.

Providing the above Personal Data is a necessary condition for scheduling a test drive. Otherwise, we will not be able to respond to an inquiry related to a test drive.

The above Personal Data is stored in the Company’s database until You revoke Your consent.

Personal data provided by other persons

There are cases when You may provide us with the personal data of third parties, e.g. in order to prepare and deliver a promotional offer that You believe may be interesting to someone You know, in which case we will consider that You have been authorized by such person to do so, and in no case will we bear responsibility for the processing of the Personal Data of the third party.

Purpose of data collection

The purpose of data collection is:

  • compliance with the Company’s legal obligations (contractual and statutory),
  • conclusion and performance of motor vehicle sales contracts, motor vehicle use contracts, and vehicle servicing contracts;
  • fulfillment of pre-contractual obligations (scheduling test drives, scheduling vehicle services, control service inspections of vehicles, information on repair prices, drawing up an offer for the purchase of a vehicle or vehicle repair, etc.);
  • vehicle servicing, procurement of spare parts, sending reminders for a scheduled service, performing other requested work on the vehicle,
  • vehicle recall or replacement of certain defective parts,
  • establishing contact and providing Clients with the opportunity to be informed about offers and additional information and news of interest to them regarding the Company and the goods and services of this company, as well as for the purpose of exercising the rights of Clients related to purchased products/services provided
  • pursuing the legitimate interests of the Company as controller or of a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subjects that require the protection of personal data.

Legal basis for data processing and method of data collection

The legal bases for data processing are:

Your consent

Your Personal Data obtained on the basis of Your consent will be processed and stored for as long as Your consent exists, i.e. until a possible revocation of Your consent. You may revoke your consent for the collection, processing and use of Your data at any time by sending an electronic request to the email address: zastitapodataka@deltaautomoto.rs.

The revocation of consent does not affect the lawfulness of the processing of Personal Data carried out on the basis of Your consent before the revocation.

Performance of contractual obligations

The Company collects Personal Data that is necessary for it to conclude and perform a contract with You and to fulfill pre-contractual obligations (e.g. sending offers). Certain data in the forms through which You send us Your requests are marked as mandatory. They are necessary for concluding a contract, i.e. they are needed so that we can respond to Your requests and fulfill them, or so that we can fulfill our legal or contractual obligations.

If You do not provide us with the necessary Personal Data, we will not be able to process Your request or conclude a contract. The purpose of processing other Personal Data (optional Personal Data, which You are free to fill in or not) that is not necessary for the fulfillment of pre-contractual and contractual/legal obligations is to get to know You better and to send You customized promotional messages. In relation to them, You have the right to request the deletion of Personal Data from our database at any time.

Legitimate interest

The Company processes Personal Data for the purpose of protecting the legitimate interests of the Company and the legitimate interests of third parties. The legitimate interests of the Company particularly include: maintaining the functionality of IT systems, and preventing abuse, i.e. fraud in establishing warranty rights.

Compliance with legal obligations

To the extent that the processing of Your Personal Data is necessary for the fulfillment of the Company’s legal obligations, i.e. obligations defined by various laws.

Protection of vital interests

We process certain Personal Data so that we can contact and notify You in the event that it is necessary to recall a vehicle or remedy a defect that could endanger Your life and/or safety.

Recipients and third parties

We also disclose Personal Data to certain recipients, i.e. third parties: our affiliated entities in the territory of the Republic of Serbia, the manufacturer of vehicles and/or parts in the Company’s sales assortment, marketing companies, communication services or companies for market research or client satisfaction research, and insurance and leasing companies, which are engaged by or cooperate with the Company, all for the purpose of providing information and data related to the sale of vehicles and the provision of service services and their improvement, for communication about vehicle safety campaigns, communication about marketing and promotional activities, for the improvement of those activities, etc., as well as for carrying out other business activities in which the Company engages.

The Company will not make Your Personal Data available to other recipients, i.e. third parties, except in the cases specified in this Notice.

Retention period of Personal Data

Data that the Company collects on the basis of law as the legal basis must be retained for as long as is determined by the particular law or other positive regulation.

Data that the Company collects on the basis of a contractual relationship is stored permanently.

Data that is processed exclusively on the basis of Your consent is stored until the revocation of consent.

Data that is processed for the protection of vital interests is stored permanently.

Client’s rights in relation to the processing of Personal Data

In addition to the rights already stated in this Notice, as well as other rights provided by the Law and other regulations in accordance with the Law, the data subject (Client) has the right to:

  • request from the Company information on whether it processes his/her Personal Data and access to that data;
  • request from the Company the rectification, supplementation or erasure of his/her Personal Data, and the right to object to processing;
  • file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection;
  • have his/her inaccurate Personal Data rectified without undue delay. Depending on the purpose of processing, the person has the right to supplement his/her incomplete Personal Data, including by providing an additional statement;
  • have the processing of his/her personal data restricted by the Company if one of the following cases is met:
    1. the data subject contests the accuracy of the Personal Data, for a period enabling the Company to verify the accuracy of the Personal Data;
    2. the processing is unlawful, and the data subject opposes the erasure of the Personal Data and requests the restriction of their use instead;
    3. the Company no longer needs the Personal Data for the purpose of processing, but the data subject has requested them for the establishment, exercise or defense of a legal claim;
    4. the data subject has objected to processing pursuant to Article 37, paragraph 1 of the Law, and an assessment is under way as to whether the controller’s legal basis for processing overrides the interests of the data subject.

The Company is obliged to inform all recipients to whom the Personal Data has been disclosed of any rectification or supplementation or erasure of Personal Data or restriction of their processing in accordance with the Law, unless this is impossible or requires disproportionate time and resources. The Company is obliged to inform the data subject, at his/her request, about all recipients.

The data subject has the right to receive the Personal Data that he/she has previously provided to the Company from it in a structured, commonly used and electronically readable form, and has the right to transmit this data to another controller without hindrance from the controller to which the data was provided, in accordance with the Law.

If he/she considers it justified in relation to the particular situation in which he/she finds himself/herself, the Client to whom the data relates has the right to object to the Company at any time to the processing of his/her Personal Data, in accordance with the Law.

The Client to whom the data relates has the right not to be subject to a decision based solely on automated processing, including profiling, if that decision produces legal effects concerning that person or significantly affects his/her position.

Procedure in the event of a Personal Data breach

If a Personal Data breach may result in a high risk to the rights and freedoms of natural persons, the Company is obliged to notify the data subject of the breach without undue delay, in accordance with the Law.

In the event of a Personal Data breach that may result in a risk to the rights and freedoms of Clients, the Company is obliged to notify the Commissioner for Information of Public Importance and Personal Data Protection without undue delay or, where feasible, within 72 hours of becoming aware of the breach. The notification submitted to the competent authority contains all information in accordance with the Law.

Transfer of Personal Data to other countries

The transfer of Personal Data to another country or an international organization, without prior approval, may be carried out if it has been established that that other country/international organization ensures an adequate level of protection of personal data. In this regard, the Decision on the list of countries, parts of their territories or one or more sectors of specified activities in those countries and international organizations in which an adequate level of protection of personal data is considered to be ensured (“Official Gazette of RS”, no. 55/2019) (hereinafter: “the Decision”) determines where an adequate level of protection of personal data is considered to be ensured.

The companies to which the Company transfers data are headquartered in the Federal Republic of Germany, Japan, Great Britain, Hungary, the Swiss Confederation and the United States of America (limited to the “Privacy Shield framework”), for which it has been established in accordance with the Decision that they ensure an adequate level of protection of personal data.

The Company may transfer clients’ personal data to the People’s Republic of China by applying the exception from Article 69, paragraph 1, point 5 of the Law, where such a transfer is necessary for the establishment, exercise or defense of a legal claim. A transfer on this basis will be carried out exclusively in special, individual cases, in response to a specific request from a company from the People’s Republic of China, after the Company has determined that the transfer is necessary for handling the specific legal claim. Only data that is necessary for the stated purpose is transferred, to the extent necessary for handling the specific case. This exception does not constitute a basis for regular or routine transfer of data to a company in the People’s Republic of China.

Links to third-party websites and services

Our website may contain links to third-party websites. Please note that we are not responsible for the collection, use, maintenance, sharing or disclosure of data and information by third parties. If you provide information on third-party sites and use those sites, the privacy rules and terms of use of those third parties will apply. We recommend that You read the privacy rules of the websites you visit before submitting personal data.

By clicking the Facebook, Twitter, Instagram or YouTube button on our website, you accept the possibility that data about Your visit to our website may be processed by those social networks if you have an account on them. To avoid this situation, We advise You to first log out of Your user accounts on these social networks, and only then, by clicking the link on our website, visit our page on one of the mentioned social networks.

Data confidentiality and transparency

Your Personal Data will be treated as confidential information and the Company will take the appropriate necessary measures to protect it in accordance with the Law. Access to it will be granted only to persons who, given the description of the work they perform, need to be familiar with Your personal data, and only to the extent necessary for the performance of their duties.

This Privacy Policy is available on the website avatrbalkan.com and avatr.rs as well as in the Company’s showrooms.

If we decide to change our Privacy Policy, the changes will be posted and published on the website avatrbalkan.com and avatr.rs and in the Company’s showrooms.

If you have any questions or requests regarding the processing of Your personal data, please contact us at: zastitapodataka@deltaautomoto.rs.

Yours,
Delta Automoto