PRIVACY POLICY
PRIVACY POLICY
CONTENTS
- INTRODUCTION
- DATA COLLECTION, PROCESSING AND USE
- CONTACT DETAILS OF THE RESPONSIBLE MANUFACTURER AND DATA PROTECTION MANAGER
- KIND OF PERSONAL DATA WE COLLECT ABOUT YOU
- HOW YOUR PERSONAL DATA IS COLLECTED
- PURPOSES OF TREATMENT & THE LEGAL BASIS OF TREATMENT OF YOUR DATA
- WHO ARE THE RECIPIENTS OF YOUR DATA
- TRANSMISSION OF PERSONAL DATA RELATING TO YOU IN THIRD COUNTRIES
- FOR HOW LONG DO WE STORE YOUR DATA
- HOW WE ENSURE THE SECURITY OF YOUR DATA
- YOUR RIGHTS AS A DATA SUBJECT AND HOW YOU CAN EXERCISE THEM
- THE USE OF COOKIES
- LEGAL BASIS OF PROCESSING PERSONAL DATA
- SECURITY MEASURES OF INFORMATION LOCATION
INTRODUCTION
This Privacy Policy (hereinafter referred to as "the Policy") concerns the company "HDKA Athena Motors Ltd." (hereinafter referred to as "the company") and the personal data that the company keeps for individuals. Information for companies and other entities is not included in the scope of this Policy. For the Company the protection of personal data is of paramount importance. For this reason we would like to inform you that we are protecting the privacy of your information when you provide us with your personal information. Of course, data protection regulations are followed, but in addition, by giving you this information, you are committed to using your data responsibly, ensuring that its Privacy is protected at all times. We want you to feel safe when you visit our website.
DATA COLLECTION, PROCESSING AND USE
Harley-Davidson® Athena, HDKA Athena Motors Ltd. (hereinafter referred to as the Company) for the purpose of better informing its customers and promoting its sales uses a CRM (Customer Relationship Management) system. With the specific system: 1. Carries out campaigns for the promotion of corporate products and services to existing customers, as well as to potential customers who have stated that they accept the relevant information. 2. Manages and monitors all sales opportunities. 3. Manages all incoming support requests of existing and potential customers regardless of the way of entering the company (e-mail, website contact form or alternatively telephone call, fax, etc.). 4. Exports reports and statistics which are used in business decision making. Data can be accessed using desktop or handheld computers, either through the internal network or through a secure Internet connection or by sending locked files with hidden passwords. The Company maintains in CRM the data of the customers which they agree to mention with emphasis on what is related to the possibility of successful sale. It does not request or add from its own or third party sources sensitive personal data, such as elements of religious beliefs, political views, racial or ethnic origin, etc.
CONTACT DETAILS OF THE RESPONSIBLE MANUFACTURER AND DATA PROTECTION MANAGER
HDKA Athena Motors LTD. is responsible for the processing of personal data concerning you, and its affiliates may also process your personal data, as set forth in this Policy, which is processed in the context of the provision of products and services
KIND OF PERSONAL DATA WE COLLECT ABOUT YOU
The following categories of data about you may be collected and further processed through the various services and media described in this Policy: (a) Contact Data ► eg name, address, telephone numbers, email address, no. fax. (b) Personal Information ► eg date of birth, marital status, family members, driving license (type), occupation, test ride, hobby, preferred payment method, preferred channel of communication, no. Vehicle Chassis (VIN), company name. (c) Interests ► information you provide to us about your interests, including the type of vehicles you are interested in. (d) Use of Website & Communication ► how you use our website and whether you open or promote our communications, including information collected through cookies (our company Cookies Policy which is available here and determines the relevant details). (e) Historical Customer Information ► eg Customer Satisfaction Rates, Bids Received, Vehicle Purchase Data Including Model, Configuration, Purchase Date, Registration Date, License Plate Number, Order Date, Delivery Date, Vehicle Owner, Purchase Price, Warranty Information, Residual value , spare parts, accessories and lifestyle product data, data collected during visits to HDKA Athena Motors Ltd. (eg requests, consulting information, sales consultant, repair history), campaign history / campaign results, optional customer data for other vehicle manufacturers, participation in events (location, company), complaint history, repair history. (f) Use of Device and Service ► how you use your device (mobile or vehicle) and the service provided on the device. 4 (g) Vehicle Configuration Elements ► information about the characteristics and current settings of your vehicle (as identified by the Vehicle Chassis Number (VIN)). (h) Vehicle Technical Information ► information on current or past performance of the engine and systems in the vehicle, fuel level, residual distance (free flow), RTTI data (navigation data entry), outside temperature, mileage, average speed. (i) Vehicle / Device Location Information ► the location of your vehicle or mobile device.
HOW YOUR PERSONAL DATA IS COLLECTED
We collect information about you, including in the following cases: When you contact us directly, through our call center or our website, to request information about the products or services we offer. If you purchase a product or service directly from us. If you respond to our actions for the purpose of direct marketing, eg by filling out a response card or entering your data online on our website. If your personal data is transmitted to us by Merchants or other third parties. If your vehicle data (including chassis number) is transmitted to HDKA Athena Motors Ltd. while your vehicle is undergoing maintenance or repair work eg in authorized workshops. If trading partners legally transmit your personal data to us. . Occasionally, by third parties who may legally provide us with information about you or whose files we may have legal access to. If you provide personal data on behalf of a third party, you should ensure that such third party is aware of this Policy in advance. CHILDREN We do not knowingly collect any personal information from children under the age of eighteen (18) without parental consent, unless permitted by law. If you are under 18 please do not provide information about yourself unless you have the consent of the person holding your parental care.
PURPOSES OF TREATMENT & THE LEGAL BASIS OF TREATMENT OF YOUR DATA
The use of personal data in accordance with European Union law on the protection of personal data must be based on one of the "legal bases" and we must identify the legal processing bases in relation to any use of data under this Policy. An explanation of the legal basis for processing is available here. (i) Vehicle Sales & Service - to process the sale to you, the configuration and service of your vehicle [Article 6 (1) (b) and 6 (1) (f) GDPR] ► The company will receive Contact Information, Vehicle Configuration Information, Vehicle Technical Information and Sales and Service Information, as well as Customer History Information when purchasing a vehicle or performing maintenance or repair work on a vehicle as part of the sale or service, including receivables. warranty and checks, and will use this information to provide you with the services you request and to inform you about issues related to your vehicle. HDKA Athena Motors Ltd. may access such information to resolve technical or other issues related to the provision of such services. The above processors may also receive limited Vehicle Location Information during the repair process, which will only be used in accordance with the Location Information Security Measures (link). The provision of personal data in the context of Vehicle Sales & Service is a contractual obligation and their non-provision will affect the proper execution of the contract or will make it impossible. (ii) Customer Support and Marketing - to answer questions and stay informed about our news and promotions [Article 6 (1) (a) and 6 (1) (f) GDPR] HDKA Athena Motors Ltd. collects Contact Data, Personal Data, Interests, Website and Contact Usage Data and Customer History Information, as well as Device and Service Usage Data, and may use Sales and Service Information, Information and Services, Information which it receives from you through the website harleydavidsonathena .gr, and information about when your current funding product expires, in order to determine which news and which offers you may be most interested in and to contact you about these offers according to your marketing preferences. If you consent, we will create your 7 personalized profile through statistical procedures to offer you personalized offers. Consent on marketing can be revoked at any time, with effect for the future. Quality Assurance, Research and Development - to improve our products and services [Article 6 (1) (f) GDPR] ► HDKA Athena Motors Ltd. may use any of the information obtained through the provision of services to Harley-Davidson Inc., in an impersonal (anonymous) form for product and service quality assurance and development purposes. Prior to any such use, your information will be depersonalized (anonymous) so that they will not be able to link directly to you. (vi) Compliance with binding requests for your data - to comply with our legal obligations to police, regulatory and judicial authorities and services [Article 6 (1) (c) GDPR] ► 6 with these laws. Such compliance includes providing your information to police, regulators and courts, as well as third parties in connection with litigation or investigations anywhere in the world, where we have an obligation to do so. Where permitted, we will forward any such request to you or notify you before we respond, unless such action would jeopardize the prevention or detection of criminal activity. The provision of personal data in order to comply with binding requests for your information is a statutory obligation which depends on this request. (vii) Product recall - in the event that it becomes necessary to withdraw Harley-Davidson products from the market [Article 6 (1) (c) and 6 (1) (f) GDPR] ► In case a Harley-Davidson product has to be recalled from the market due to eg HDKA Athena Motors Ltd. will process your personal data to contact you and carry out this process.
WHO ARE THE RECIPIENTS OF YOUR DATA
The personal data we collect, eg for the provision of Boom Audio Services, may be transmitted to third parties, provided that the legality of the transmission is justified. Furthermore, if the legality of the transfer is justified, your personal data may be disclosed to the following categories of recipients: Har Harley Davidson Inc. affiliates and affiliates providing Harley-Davidson Products or Services.
Other authorized Harley-Davidson service dealers Service providers providing services on your behalf, such as IT and mail providers .) if you have agreed to this. We may also share your information with third parties, including law enforcement and the courts, for legal or regulatory or fraud prevention purposes, as well as prospective buyers if you sell your business. (a) Any person who may process your personal data under our instructions and on our behalf. (b) Companies of the Harley-Davidson Group Inc, including its subsidiaries, Harley-Owners Group and HDKA Athena Motors Ltd., Athens Branch, and other companies of the Harley-Davidson Group, within the scope of their responsibilities and in accordance with the provisions of the law for international data transmissions, if applicable. (c) Merchants and other associates. (d) Companies that provide HDKA Athena Motors Ltd. services, such as IT maintenance service providers, IT hosting, Customer Interaction Center. (e) Any supervisory authority, as the case may be required by the applicable supervisory framework. (f) Any public or judicial authority, as required by law or court decision. HDKA Athena Motors Ltd. and Harley-Davidson Inc. use a number of service providers to assist in providing the services and uses listed. Harley-Davidson Inc. provides IT and storage services to HDKA 9 Athena Motors Ltd. in connection with the majority of these uses described above and therefore stores most of your information described in detail above on behalf of HDKA Athena Motors Ltd. Although the transmission of data via the Internet or a website cannot be guaranteed against cyber attacks, both we and our subcontractors and partners work hard to maintain physical, electronic and procedural security measures to protect your data in accordance with applicable data protection requirements. All information about you is stored on secure servers by us or our subcontractors or partners (or in hard copy) and access to and use of it is subject to our policies and standards (or equivalent subcontractor standards or of our partners).
TRANSMISSION OF PERSONAL DATA RELATING TO YOU IN THIRD COUNTRIES
Your personal data is preferably processed within the European Union. If your personal data is processed in countries outside the European Union, we will ensure that your personal data is processed under appropriate security guarantees. Some countries outside the European Union, such as Canada and Switzerland, have already been formally recognized by the European Union as providing countries with an adequate and equal level of data protection. Therefore, the transmission of data to these countries does not require any special authorization or agreement. In countries for which no relevant decision has been taken, such as India or Japan, we will either seek your consent for the transmission or we will transmit the data on the basis of the contractual clauses approved by the European Commission imposing corresponding data protection obligations directly on the recipient, unless the applicable laws on the protection of personal data allow us to make such transmissions without complying with these formalities.
FOR HOW LONG DO WE STORE YOUR DATA
We store your personal data for as long as is required by the respective processing purpose and any other permitted linked purpose (for example, in defending a claim against us). Therefore, in case the data is used for two purposes, we will keep it until the purpose with the longest time expires, but we will stop using it for the purpose with the shortest time as soon as that time has passed. Information that is no longer needed is either returned anonymously (and information that has become anonymous can be retained) or is safely destroyed. In particular, the data concerning you are retained throughout the duration of your business relationship with HDKA Athena Motors Ltd., after its expiration, for as long as the current legislation provides that claims may be raised by the parties or, in case of a claim , until the irrevocable resolution of any dispute. Especially for the data that concern you and which we process based on your consent (eg for marketing purposes), these are kept from obtaining the relevant consent and until you revoke it. We restrict access to your data to persons who need to use it for that purpose.
HOW WE ENSURE THE SECURITY OF YOUR DATA
We ensure the data that concerns you according to the latest technology. For example, the following security measures are used to protect your personal data against misuse or any other form of unauthorized processing: access Access to personal data is restricted to a limited number of authorized persons and for specific purposes. The collected data is transmitted only in encrypted form.
In addition, sensitive data is only stored in encrypted form. The IT systems used to process the data are technically isolated from other systems in order to prevent unauthorized access, for example through hacking. In addition, access to these IT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. In the event that we give you (or have chosen) a password to access certain parts of our website or any other web portal, applications or services we offer, you are responsible for maintaining that password and complying with all procedures. security, of which we have informed you. Please do not share your password with anyone.
YOUR RIGHTS AS A DATA SUBJECT AND HOW YOU CAN EXERCISE THEM
You have the right to request access to your personal data, the correction / deletion of your personal data, the restriction of processing, the right to object to the processing and / or to exercise your right to data portability. If the data processing is based on your consent, you may revoke your consent at any time, with effect for the future. HDKA Athena Motors Ltd. will review your request and respond to you within one month of receiving the request or, taking into account the complexity of the request and the number of requests, within two months. In the event that you are not satisfied with the use of your data by us or with our response to the exercise of your above rights, you have the right to file a complaint to the supervisory authority. You can exercise your above rights by contacting HDKA Athena Motors Ltd. at the contact details listed below: Tel. +30 210 3410850 Fax +30 210 3410859 The opening hours of the Customer Communication Center of HDKA Athena Motors Ltd. are: Monday - Friday, 9:00 - 21:00 and Saturday, 9:00 - 17:00 General information If you visit the website of the Company general information is collected automatically. This information includes, for example, information such as the type of browser, operating system or domain of the ISP you are using. Only information is collected that does not allow any conclusions to be drawn regarding your identity. In addition, this information is also generated during the visit of any other website on the internet and is a function that does not specifically concern the Company's website. This type of information is collected exclusively anonymously and is used exclusively for statistical purposes. The better we understand what you want, the faster you will find the information you want on your web pages. Links to other third party websites The website may contain links to third party websites. You are not responsible for the security or privacy of the information collected from these sites. We recommend that you review the privacy policy statements that apply to third party websites to understand how they collect your information. Security The Company applies technical and organizational security measures to protect your personal data from any intentional or fraudulent, loss, destruction or access by unauthorized persons. Security measures are being improved and adapted on a regular basis according to the latest technologies. Changes to the policy Retain the right to change this policy. In this case, we will publish a revised privacy policy on our website.
THE USE OF COOKIES
LEGAL BASIS OF PROCESSING PERSONAL DATA
Use of the information about you, as described above, is permitted under European Union data protection law under the following legal conditions: You have consented to the use (you will be given a consent form in respect of any such use and you may revoke the your consent). When it is necessary for the conclusion or execution of the contract between us. When their use is necessary to comply with our legal obligations. When their use is necessary for the purposes of our legitimate interests and our interests take precedence over your data protection rights (our legitimate interests include the research and development of vehicle-related products and services). When it is necessary to support, exercise or raise legal claims against you or against a third party. There may be uses permitted for other legal reasons. In this case, we will determine the legal basis and inform you as soon as possible after we become aware of this new processing basis. The legal basis on which the processing of each use of your data is based is stated next to each processing purpose.
SECURITY MEASURES OF INFORMATION LOCATION
Some information may only be offered when you publish your location or the location of your vehicle. We take the confidentiality of this location information very seriously. The following security measures apply to Location Information (including information that is accessible as part of the vehicle service process): They are stored only in a form related to you or your vehicle for as long as is necessary to fulfill the purpose for which you have consented. They are only received or accessed in this form, where it is deemed necessary to provide the requested service or where we are required to comply and / or provide by law (and where we are required to provide information to police authorities or anyone else thirdly , we will inform you unless our action in question would jeopardize the prevention or detection of a criminal act or if we are not allowed to do so). Vehicle Location Information and Device Location Information are not linked unless required to provide the requested service. Other Any other use of the Location Information for analytical purposes will be made on data sets that have been returned anonymously. Both we and our network members may have access to Vehicle Location Information and Harley-Davidson Inc. and its affiliates, or HDKA Athena Motors Ltd. may access Device Location Information through the services we provide. You will be provided with a detailed description of the location information obtained for providing the location information-dependent service when you first purchased the vehicle or activated or configured the service or application.
Please note that we may not be able to provide you with certain features of our services if you limit the collection of your location information.
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