1. Privacy Policy

Version from 04/21/2022

In this data protection declaration, we explain how we collect and otherwise process personal data. This data protection declaration is not final; if necessary, other data protection declarations, general terms and conditions or conditions of participation, contracts and similar documents regulate specific matters. Personal data means all information that relates to a specific or identifiable person.

If you provide us with the personal data of other people (e.g. family members or data from work colleagues), please ensure that these people are aware of this data protection declaration and only provide us with their personal data if you are permitted to do so and the data subjects agree to it , and if this personal data is correct.

2. Controller / Representative

The company named in the imprint is responsible for the data processing that we describe here, unless otherwise stated in individual cases. If you have data protection concerns, you can send them to us at the contact address given in the imprint. In the event of requests for information or deletion, enclose a copy of your ID. You can also address your concerns to us using the contact details provided in the imprint.

3. Collection and processing of personal data

We primarily process the personal data that we receive from our customers and other business partners as part of our business relationship with them and other people involved, or that we collect from their users when operating our websites, apps and other applications.

Insofar as this is permitted, we also obtain certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, the press or the Internet) or receive such data from other partners, from authorities and other third parties (e.g. credit information agencies or address brokers). In addition to the data you give us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process business with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (insofar as we conduct business with you personally), information about you, persons from us Give your environment (family, consultants, legal representatives, etc.) so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries or powers of attorney), information on compliance with legal requirements such as combating money laundering and Export restrictions, information from banks, insurance companies, sales and our contractual partners for the use or provision of services by you (e.g. payments made or purchases made), information from the media and the Internet about you (if this is indicated in the specific case, e.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing) or data in connection with the use of websites (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, Date and time of visit, pages and content accessed, functions used, referring website or location information).

4. Purposes of data processing and legal bases

We use the personal data we collect primarily to conclude and process our contracts with our customers and business partners, in particular in the context of vehicle trading, repairs, financing and rental of vehicles and the purchase of products and the provision of Services provided by our suppliers and their subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, your personal data may also be affected in this function.

In addition, we process personal data of you and other persons, as far as permitted and it seems appropriate to us, also for the following purposes, in which we (and sometimes also third parties) have a legitimate interest corresponding to the purpose:

- Offer and further development of our offers, services and websites, apps and other platforms on which we are present;

- Communicating with third parties and processing their inquiries (e.g. job applications or media enquiries);

- Examination and optimization of processes for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;

- Advertising and marketing (including the organization of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time; we will then place you on a blacklist against further advertising mailings) ;

- Market and opinion research, media monitoring;

- Assertion of legal claims and defense in connection with legal disputes and official proceedings;

- Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations or data analysis to combat fraud);

- Guarantees of our operation, in particular the IT, our websites, apps and other platforms;

- Video surveillance to protect domiciliary rights and other measures for IT, building and plant security and protection of our employees and other people and assets belonging to or entrusted to us (such as access controls, visitor lists, network and mail scanners or telephone recordings);

- Purchase and sale of business areas, companies or parts of companies and other corporate transactions and the associated transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations.

If you have given us your consent to process your personal data for specific purposes (e.g. when registering to receive newsletters or carrying out a background check), we will process your personal data within the framework of and based on this consent, unless we have another legal basis and /or we need one. A given consent can be revoked at any time, but this has no effect on data processing that has already taken place.

5. Cookies / tracking and other technologies related to the use of our website

We typically use "cookies" and similar techniques on our websites and apps that allow your browser or device to be identified. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website or install an app. If you visit this website again or use our app, we can recognize you in this way, even if we do not know who you are. In addition to cookies that are only used during one session and are deleted after your website visit ("session cookies"), cookies can also be used to save user settings and other information for a certain period of time (maximum two years) ("permanent cookies "). However, you can set your browser so that it rejects cookies, only saves them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g. language or auto login), so that we can better understand how you use our offers and content and so that we can show you offers and advertising tailored to you. Corresponding functions can also be used by our contractual partners, who in this context find out, for example, which users of our website are also visiting their website. Under no circumstances do they find out from us who they are; if we should even know it ourselves. ). Certain cookies are set by us, some by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart or ordering processes) may no longer work.

In some of our newsletters and other marketing e-mails, and to the extent permitted, we include visible and invisible image elements which, by retrieving them from our servers, enable us to determine whether and when you opened the e-mail so that we can measure and better understand it how you use our offers in order to be able to tailor them to you. You can block this in your e-mail program (most e-mail programs are already set up this way).

By using our websites, apps and consenting to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, you must set your browser or e-mail program accordingly, uninstall the app (if this cannot be adjusted via the settings) or unsubscribe from the newsletter.

We sometimes use Google Analytics or similar services on our websites. These are services provided by third parties, which may be located abroad (in the case of Google Analytics, this is Google LLC in the USA, [www.google.com](http://www.google.com)). With the services of these third parties, we can measure and evaluate the use of the website (not personal)[; this information, which is also non-personal, can also be used by certain of our contractual partners (e.g. Volkswagen)]. Permanent cookies are also used for this purpose, which are set by these service providers. These service providers do not receive any personally identifiable information from us (nor do they keep any IP addresses), but they may track your use of the website and combine this information with data from other websites that you have visited that are also tracked by these service providers and this Use findings for your own purposes (e.g. control of advertising). If you have registered yourself with these service providers, these service providers also know you. The processing of your personal data by these service providers is then the responsibility of the service providers in accordance with their data protection regulations. The service providers only tell us how our respective website is used, and no information about you personally is given.

We also use so-called plug-ins from social networks such as Facebook, Twitter, YouTube, Google+, Pinterest or Instagram on our websites. You can see this in each case (typically via the corresponding symbols). We have configured these items to be disabled by default. If you activate this (by clicking), the operators of the respective social networks can register that you are on our website (especially where within our websites) and can use this information for their purposes. The processing of your personal data is then the responsibility of these operators according to their data protection regulations. We do not receive any information about you from them.

6. Data transfer and data transmission domestically and/or abroad

In order to provide our services, we rely on the internal and external transfer of personal data. We therefore also disclose personal data to third parties as part of our business activities, insofar as this is permitted by the purpose in accordance with Section 4 and we deem it appropriate; be it because they process it for us or because they want to use the data for their own purposes. In particular, this concerns the following positions:

- Our service providers such as banks or insurance companies, including processors (such as IT providers);

- dealers, service partners, suppliers, subcontractors and other business partners;

- Customers;

- domestic and foreign authorities, official offices or courts;

- Media;

- the general public, including website and social media visitors;

- Competitors, industry organizations, associations, organizations and other bodies;

- Acquirers or those interested in acquiring business areas, companies or other parts;

- other parties in potential or actual legal proceedings;

all common recipients.

If necessary for the provision of our services and taking into account the intended purpose, personal data will be transmitted to the above-mentioned bodies inside and outside of Switzerland and the EU. In particular, you must expect your data to be transferred to all countries in which we  is represented by group companies, branches or other offices (this is Switzerland and Liechtenstein) as well as in other countries in Europe and the USA where our service providers are located (such as Microsoft, SAP, Amazon or Salesforce). If we transfer data to a country without adequate statutory data protection, we will ensure that the relevant contracts and/or measures are used as required by law (specifically on the basis of the so-called standard contractual clauses of the European Commission, which [here](http://eur-lex .europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF), [here](http://eur-lex.europa.eu/LexUriServ/LexUriServ. do?uri=OJ:L:2004:385:0074:0084:DE:PDF) and [here](http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001D0497:DE :HTML) are available) or so-called Binding Corporate Rules for an appropriate level of protection or rely on the statutory exceptions of consent, contract processing, the determination, exercise or enforcement of legal claims, overriding public interests, the publication of personal data or because it is Protection of the integrity of the persons concerned is necessary. However, we reserve the right to black out copies or only publish excerpts for data protection reasons or reasons of secrecy.

7. Duration of storage of personal data

We process and store your personal data as long as it is necessary to fulfill our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, processing to the termination of a contract and the warranty period and a subsequent support phase) as well as in accordance with the statutory retention and documentation obligations. It is possible that personal data will be stored for the time in which claims can be asserted against us and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above purposes, it will be deleted or made anonymous as far as possible. In some cases, shorter retention periods apply to operational data (e.g. system protocols or logs).

8. Data Security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions and conducting training courses, IT and network security solutions, access controls and restrictions, pseudonymization and controls.

9. Obligation to provide personal data

As part of our business relationship, you must provide the personal data required to establish and conduct a business relationship and to fulfill the associated contractual obligations (as a rule, you do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude or process a contract with you (or the body or person you represent). Our websites can also only be used if certain information to ensure data traffic (such as IP address) is disclosed.

10. Profiling and Automated Decision Making

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to be able to provide you with targeted information and advice about products. We use evaluation tools that enable us to communicate and advertise as needed, including market and opinion research.

In principle, we do not use automatic decision-making (as regulated, for example, in Art. 22 of the General Data Protection Regulation of the European Union (GDPR)) to establish and implement the business relationship or otherwise. If we use such procedures in individual cases, we will inform you separately, if this is required by law, and explain the associated rights to you.

11. Rights of the data subject

Within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR), you have the right to information, correction, deletion, the right to restriction of data processing, a right to object to our data processing and the right to the disclosure of certain personal data for the purpose of Transmission to another location (so-called data portability). Please note, however, that we reserve the right to assert the statutory restrictions on our part, for example if we are obliged to store or process certain data, have an overriding interest in this (to the extent that we can invoke this) or you need them for the assertion of require claims. In principle, a request for information is free of charge. A fee may be charged in the case of a particularly large amount of work, excessive or notorious requests for information, provided there is no legitimate interest. If you incur any costs, we will inform you in advance. For the possibility of revoking your consent, we refer to Section 4. Please note that the exercise of these rights can conflict with contractual agreements and this can have consequences such as premature termination of the contract or financial consequences. We will inform you in advance if this is not already contractually agreed.

Exercising these rights presupposes that you clearly prove your identity (e.g. by means of a copy of your ID, where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in Section 2.

Each data subject also has the right to enforce their claims in court or to lodge a complaint with the responsible data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch). In Liechtenstein, the Liechtenstein Data Protection Commission ([www.datenschutzkommission.li](http://www.datenschutzkommission.li)) is responsible.

12. Changes

We can adjust this data protection declaration at any time without prior notice. The current version published on our website applies. Insofar as the data protection declaration is part of an agreement with you, we will inform you of the change in the event of an update if this can be done without disproportionate effort.