Global Privacy Statement
Last updated: 25 May 2025
Your privacy is important to us and to Société Générale Group to which Ayvens belongs. This is a matter of priority for us and we have implemented strong principles in that respect, especially in regards of the EU General Data Protection Regulation. Ayvens S.A. and its affiliated entities (hereafter “Ayvens”) value the trust of customers, suppliers and business partners and are committed to protecting their personal data. Compliant privacy and information security practices are therefore integral components of Ayvens’ services, corporate governance, risk management and overall accountability. We only process such personal data as is necessary for our business activities and the provision of the Ayvens services.
This Global Privacy Statement (the “Statement”) describes our practices in connection with the personal information (“Personal Data”) that we process about you and your business relationship with Ayvens.
Please read this Global Privacy Statement carefully so that you understand how we collect and use your Personal Data.
Table of contents
- 1.
SCOPE OF THIS STATEMENT
- 2.
WHO ARE WE?
- 3.
HOW DO WE COLLECT YOUR PERSONAL DATA?
- 4.
WHY AND ON WHICH LEGAL BASIS DO WE USE PERSONAL DATA?
4.1 DATA PERTAINING TO WEBSITE VISITORS
4.2 DATA PERTAINING TO CUSTOMERS
4.3 DATA PERTAINING TO DRIVERS (EMPLOYEES OF OUR CUSTOMERS)
4.4 DATA PERTAINING TO PRIVATE LEASE CUSTOMER (INCLUDING SOLE PROPRIETORS AND PARTNERSHIPS)
4.5 DATA PERTAINING TO PRIVATE BUYERS OF USED VEHICLES
4.6 DATA PERTAINING TO PROFESSIONAL BUYERS OF USED VEHICLES (TRADERS)
4.7 DATA PERTAINING TO SUPPLIERS
4.8 DATA PERTAINING TO BUSINESS PARTNERS
- 5.
WHO HAS ACCESS TO YOUR DATA?
- 6.
WHY PERSONAL DATA MAY BE TRANSFERRED TO THIRD COUNTRIES?
- 7.
CHILDREN’S PRIVACY
- 8.
DO WE USE YOUR DATA FOR OTHER PURPOSES?
- 9.
HOW LONG WILL WE KEEP YOUR DATA?
- 10.
HOW DO WE SECURE YOUR DATA?
- 11.
CHANGES TO THIS STATEMENT
- 12.
HOW CAN YOU CONTACT US?
- 13.
HOW CAN I EXERCISE MY PERSONAL DATA RIGHTS?
1. SCOPE OF THIS STATEMENT
- 1.Website visitors/users (“Website Visitors”);
- 2.Corporate Customers (“Customers”);
- 3.Customers’ employees/drivers (“Drivers”);
- 4.Private lease customer (including sole proprietors and partnerships) (“Private Lease Customers”);
- 5.Private buyers of used vehicles (“Buyers”);
- 6.Professional buyers of used vehicles (“Traders”);
- 7.Suppliers of goods and services (“Suppliers”); and
- 8.Any third party, other than a customer, buyer, trader or supplier, with a business relationship or strategic alliance (“Business Partners”). (or prospects in relation to the above; individually and collectively also referred to as “you”, “your” or “yours”).
We collect and use your Personal Data through our various vehicle and fleet leasing, fleet management and driver mobility services and in the course of performing our business activities (“Services”).
Please also note that specific services may be subject to a separate privacy statement referenced in the respective terms.
RESPONSIBILITIES OF CUSTOMERS Insofar as Customers in their capacity as employers have access to Personal Data of their employees, i.e. Drivers, the Customer is the controller responsible for the processing and use thereof in such capacity. This Statement does not apply to the processing and use of Personal Data of Drivers by Customers.
2. WHO WE ARE
The local Ayvens entity is responsible for the processing of your Personal Data (controller). For a list of the Ayvens affiliates and their locations, that jointly process and use Personal Data, see the language sign on the top right of this website.
LeasePlan Hellas Single Member SA – Commercial vehicle leasing and fleet management services Address: 6-8, AgisilaouSt., 15123 Marousi–Athens, Greece VAT EL 999599948 Tax Office KEFODE Attica
The Ayvens Group is part of Ayvens S.A. Address: 1, Rue Eugène et Armand Peugeot 92500 Rueil Malmaison, France
Ayvens may also be referred to as “we”, “our” or “us”.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We and our service providers collect Personal Data in the following ways:
Through sales activities
We commence the processing of Personal Data if you provide this, directly or indirectly via third parties, e.g. as part of an offline sales lead, registration, online contact form, inquiry by e-mail, telephone, chat and/or application, survey or price competition.
Through the Services
Most of the Personal Data we collect are in relation to the Services we provide or will be providing to you as (i) a Driver and our Customer, your employer, if you are using a company vehicle, or (ii) a Private Lease Customer. This starts with the registration of your Personal Data with respect to the vehicle to be leased (in some circumstances we may do some preliminary credit checks before this) and continues with the registration of the leased vehicle and when we communicate with you about our services, e.g., to arrange for periodic maintenance and repairs. We may also process your Personal Data when your vehicle inadvertently is involved in an accident, to ensure that we restore mobility and handle any damage, or where we are the recipient of traffic fines in relation to your leased vehicle. Next to our core-leasing activities, we also provide a number of other related services, such as e-mobility services, fuel card services, charging services, car rental services, and roadside assistance. Another service we provide relates to car remarketing, sales of used Ayvens vehicles.
Online
We collect Personal Data from you online, when:
- You visit our websites or social media channels
- Place an order over the phone or contact customer service
- Joint marketing partners share the information with us and
- You connect your social media account to your Services account or where you share information from our websites to your social media platforms, you will share certain
Personal Data from your social media account with us, for example, your name, e-mail address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account
From other sources
We receive your Personal Data from other sources, for example:
- Drivers’ employers, if you use a company vehicle
- The relevant authority (e.g., police or justice department) where we are the recipient of traffic fines or administrative charges in relation to your leased vehicle
- Public and government authorities, including public and government authorities outside your country of residence, where we are subject to sanctions and embargoes or anti-money laundering and counter terrorism regulations
- From our independent service partners who assist us in providing our leasing and other services to you, including dealerships, maintenance providers and body repair shops
- From our partnerships being for instance original equipment manufacturers or dealerships
- Publicly available databases, credit reference agencies and other sources
We need to collect Personal Data in order to provide the requested Services to you or to handle queries, comments or complaints related to our Services. If you do not provide the Personal Data requested, we may not be able to provide the Services. If you disclose any Personal Data relating to other persons to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Statement.
Monitoring of communications
Subject to applicable laws, we will monitor and record calls, e-mail, text messages and other communications we have with you. We do this for compliance with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communication systems and procedures, and for quality control and staff training purposes.
For example, where we are required by a regulator to record certain telephone lines (as relevant) we will do so. In addition, where appropriate and having regard to applicable data protection law, our monitoring will be to check for inappropriate content in communications. In very limited and specific circumstances we may conduct short term carefully controlled monitoring of your activities where this is necessary for our legitimate interests or to comply with a legal obligation. We may do this for instance where we have reason to believe that fraud or other crime is being committed, where offences are suspected and where the monitoring is proportionate to the type of the disciplinary offence, or where we suspect non-compliance with sanctions and embargoes or anti-money laundering and counter terrorism regulations to which we are subject. In particular, telephone calls may be recorded for these purposes.
4. WHY AND ON WHICH LEGAL BASIS DO WE USE PERSONAL DATA?
4.1 DATA PERTAINING TO WEBSITE VISITORS
4.1.1 WEBSITES **4.1.1.a To communicate with you** What does this purpose entail? We process your Personal Data when you contact us via one of our online contact forms, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. This processing is done for the entering into or performance of an agreement that you have with us and to pursue our legitimate interest to be able to respond to a request. Which Personal Data do we process for this purpose? For this purpose, we may collect your (business) contact details (for instance your name(s), e mail address, telephone number), license plate or registration number and any other information that you provide to us in the open text fields of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.1.1.b For surveys or other (marketing) communication** What does this purpose entail? We process your Personal Data when you complete a survey on our website or via another tool, for feedback about our websites and/or Services, with your consent or for which we have a legitimate interest to process these data (improvement of services). With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of Ayvens. When we contact you in regard of surveys or marketing communication, we will do so either by e-mail, phone, or by postal mailings (newsletters/brochures/magazines). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication or contact your local Ayvens entity via their webform for individuals’ rights on their local website or see the general contact details below. With your consent, based on your visit to a website of Ayvens, we can show you personalized advertisements outside the Ayvens website. To understand what is relevant to you, we can use manual and automated tools to analyse your personal information. Which Personal Data do we process for this purpose? For this purpose, we process your name, your address, your e-mail address and topics you may be interested in (as may be indicated by you on our website). With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.1.2 SOCIAL MEDIA **4.1.2.a To facilitate social sharing functionality** What does this purpose entail? Our websites may contain various social media sharing functionalities, such as LinkedIn, Facebook or Snapchat buttons, which, with your consent, you may use to share information provided on our websites with the social media of your choosing. Our websites may also contain links to our own social media pages, such as our LinkedIn or Facebook pages or our X feed, which you may choose to use to post feedback. Likewise, various social media websites, such as LinkedIn, Facebook, Snapchat or X, may contain Ayvens advertisements containing links to our websites. These social media websites may, with your consent, share information provided by you with us when you choose to follow a link to one of our websites. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Meta (Facebook), X, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with our social media functionalities and/or advertisements. Processing of personal information is subject to privacy policies and practices of these other organizations. Which Personal Data do we process for this purpose? For this purpose, we process your name, e-mail address, IP-address, photo, list of social media contacts and any other information that may be accessible by us when using social media functionalities. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.1.3 COOKIES AND SIMILAR TECHNOLOGIES Any processing of your Personal Data via cookies and/or similar technologies will take place in accordance with our cookie statement, available on ayvens.com or the local website of the relevant Ayvens entity.4.1.4 AYVENS BUSINESS PURPOSES **4.1.4.a Management reporting** What does this purpose entail? Personal Data for various Ayvens business-related purposes based on your consent or for which we have a legitimate interest to process these data, such as audits, developing new products, enhancing, improving or modifying our websites and Services, data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies based on your consent. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your e-mail address, your IP address, gender, date of birth, place of residence, digits of your postal code and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.1.4.b Compliance with laws and legal obligations and protection of Ayvens assets and interests** What does this purpose entail? To comply with a legal obligation or where we have a legitimate interest, we process your Personal Data as appropriate or necessary: (a)under applicable law, including laws outside your country of residence and including sectorial recommendations; (b)to comply with legal process; (c)to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d)to enforce our terms and conditions and other applicable policies; (e)to protect our operations; (f)to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g)to allow us to pursue available remedies or limit the damages that we may sustain. Which Personal Data do we process for this purpose? For this purpose, we process your name, your contact information, your correspondence with Ayvens, your use of any of our Services and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. With whom do we share your Personal Data? Only if we are required to do so by law or sectorial recommendation to which Ayvens is subject, or if we have a legitimate interest to that effect, your Personal Data will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.2. DATA PERTAINING TO CUSTOMERS
4.3 DATA PERTAINING TO DRIVERS (EMPLOYEES OF OUR CUSTOMERS)
4.4 DATA PERTAINING TO PRIVATE LEASE CUSTOMER (INCLUDING SOLE PROPRIETORS AND PARTNERSHIPS)
4.5 DATA PERTAINING TO PRIVATE BUYERS OF USED VEHICLES
4.5.1 PURCHASE **4.5.1.a Purchase of a Ayvens used vehicle** What does this purpose entail? We process your Personal Data in relation to your (potential) purchase of a Ayvens used vehicle, if applicable, the trade in of your vehicle and other related Services. This includes the execution of the purchase agreement, the delivery of Services and the settlement of the payment transaction. This processing is required for the conclusion and performance of the agreement, including assessment, acceptance of you as a customer and preliminary credit checks. Which Personal Data do we process for this purpose? For this purpose, we process your name, gender, title, (business) contact details (including your e-mail address, telephone number, name of your company), information related to your trade in vehicle and details needed to complete the transaction, including bank account information. With whom do we share your Personal Data? We may share this information with trade in parties or financial services partners. See also section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.5.2 BUYER CONTACT **4.5.2.a To communicate with you** What does this purpose entail? We process your Personal Data when you contact us via one of our online contact forms (or provide information in one of our used vehicle centres), for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. We can contact you relating to a (potential) purchase of a vehicle. This processing is required for the performance of the agreement that you have with us or with your consent. Which Personal Data do we process for this purpose? For this purpose, we process your name, gender, title, (business) contact details (including your e-mail address, telephone number, name of your company) and any other information that you provide to us in the open field entry of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.5.2.b For surveys or other (marketing) communication** What does this purpose entail? We process your personal information when we send you a survey to request your feedback on our Services, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, current and future offers, possibilities and current and future products and services of Ayvens. When we contact you in regard of surveys or marketing communication, we will do so either by e-mail or by postal newsletters/brochures/magazines (postal mailings). To understand what is relevant to you, we can use manual and automatic tools to analyse your Personal Data. If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local Ayvens entity via its webform for individual rights or use the contact details below. Which Personal Data do we process for this purpose? For this purpose, we process your name, your address, your e-mail address, and your interests (as indicated by you). With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.5.3 AYVENS BUSINESS PURPOSES **4.5.3.a Management reporting** What does this purpose entail? We process Personal Data for various Ayvens business-related purposes based on your consent or for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies, based on your consent. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your e-mail address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.5.3.b Compliance with laws and legal obligations and protection of Ayvens assets and interests** What does this purpose entail? To comply with a legal obligation or where we have a legitimate interest, we process your Personal Data as appropriate or necessary: (a)under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence (CDD), money laundering, financing of terrorism and other crimes); (b)to comply with legal process; (c)to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d)to enforce our terms and conditions and other applicable policies; (e)to protect our operations; (f)to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g)to allow us to pursue available remedies or limit the damages that we may sustain. Which Personal Data do we process for this purpose? For this purpose, we process your name, contact information, the date, place and country of birth, in case of a company of the ultimate beneficial owner of the company; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards Ayvens; your correspondence with Ayvens, your use of Services and any other information mentioned in this Statement, if such is required for one of the purposes mentioned in the previous paragraph. For counterparty due diligence (CDD) purposes we periodically also process investigation data based on sanctions, enforcement, adverse media, politically exposed persons and anti-slavery screening. For this purpose, a risk-based approach is used to ensure only necessary Personal Data is collected. Please note, multiple (trained) employees are involved to evaluate the screening results in case of a ‘hit’ (human intervention). With whom do we share your Personal Data? Only if we are required to do so by law or sectorial recommendation to which Ayvens is subject, your Personal Data will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.6 DATA PERTAINING TO PROFESSIONAL BUYERS OF USED VEHICLES (TRADERS)
4.6.1. REGISTRATION AND PURCHASE **4.6.1.a Registration as a professional trader** What does this purpose entail? To be able to purchase Ayvens Used vehicle on an auction or purchase a vehicle via our car remarketing website(s), traders need to be registered with Ayvens as a professional trader. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of an agreement, including assessment, acceptance or credit checks) or based on a legal obligation. Which Personal Data do we process for this purpose? For this purpose, we process your name, contact details (including your e-mail address, telephone number), your identification card and information related to your company including Chamber of Commerce document and VAT certificate. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.6.1.b Purchase of Ayvens used vehicles** What does this purpose entail? We process your Personal Data in relation to your (potential) purchase of an Ayvens used vehicle and/or other related Services via an auction or via our car remarketing website(s), this includes the execution of the purchase agreement, the delivery and the settlement of the payment transaction. This processing relates to the providing of Services under the conclusion and performance of the purchase agreement) and is also based on based on our legitimate interest Which Personal Data do we process for this purpose? For this purpose, we process your name, contact details (including your e-mail address, telephone number), your identification card and information related to your company including Chamber of Commerce document and VAT certificate, details needed to complete the transaction, including bank account information. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.6.2 TRADER CONTACT **4.6.2.a To communicate with you** What does this purpose entail? We process your Personal Data when you contact us via one of our online contact forms (or provide information in one of our used vehicle centres), for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. We can contact you relating to a (potential) purchase of a vehicle. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of the agreement that we have with the Trader) or with your consent. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your business contact details, your correspondence with Ayvens pertaining to your question/request and all other Personal Data you provide to us and/or which is necessary to appropriately respond to you. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.6.2.b For surveys or other (marketing) communication** What does this purpose entail? We process your Personal Data when we send you a survey to request your feedback on our Services for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, current and future offers, possibilities and current and future products and services of Ayvens. When we contact you in regard of surveys or marketing communication, we will do so either by e-mail or by postal newsletters/ brochures/magazines (postal mailings). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local Ayvens entity via its webform for individual rights or use the contact details below. Which Personal Data do we process for this purpose? For this purpose, we process your name, your address, your e-mail address, and your interests (as indicated by you). With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.6.3 AYVENS BUSINESS PURPOSES **4.6.3.a Management reporting** What does this purpose entail? We process Personal Data for various Ayvens business-related purposes based on your consent or for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies, based on your consent. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your e-mail address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.6.3.b Compliance with laws and legal obligations and protection of Ayvens assets and interests** What does this purpose entail? To comply with a legal obligation or where we have a legitimate interest, we process your Personal Data as appropriate or necessary (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence (CDD), money laundering, financing of terrorism and other crimes); (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions and other applicable policies; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. Which Personal Data do we process for this purpose? For this purpose, we process your name, contact information, the date, place and country of birth, in case of a company of the ultimate beneficial owner of the company; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards Ayvens; your correspondence with Ayvens, your use of Services and any other information mentioned in this Statement, if such is required for one of the purposes mentioned in the previous paragraph. For counterparty due diligence (CDD) purposes we periodically also process investigation data based on sanctions, enforcement, adverse media, politically exposed persons and anti-slavery screening. For this purpose, a risk-based approach is used to ensure only necessary Personal Data is collected. Please note, multiple (trained) employees are involved to evaluate the screening results in case of a ‘hit’ (human intervention). With whom do we share your Personal Data? Only if we are required to do so by law or sectorial recommendation to which Ayvens is subject, your Personal Data will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.7 DATA PERTAINING TO SUPPLIERS
4.7.1 SUPPLIER ACCOUNT MANAGEMENT **4.7.1.a To provide, manage and administer the Supplier account** What does this purpose entail? We process your Personal Data to handle day-to-day management and administration of the Supplier accounts, such as maintaining contracts, and keep you informed of all important developments concerning the services you render and other information which is relevant for the Supplier contract and account. This processing is based on the agreement that we have with you or based on a legal obligation. Which Personal Data do we process for this purpose? For this purpose, we may process business contact details and log-in details to our Supplier online accounts. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.7.1.b To communicate with you** What does this purpose entail? You can contact us by various means (such as e-mail or telephone, or via our website). In this case we use your Personal Data to answer your question/request. We can also contact you, for example, regarding day-to-day management and administration of your Supplier account. This processing is based on the agreement that we have with you or with your consent. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your business contact details, your correspondence with Ayvens pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.7.1.c For surveys or other (marketing) communication** What does this purpose entail? We process your Personal Data to send you surveys, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, for example, to keep you updated on events, current and future offers, possibilities and current and future products and services of Ayvens. We send you such surveys in the form of either a periodic e-mail or an e-mail to request your feedback on our communication and relationship. We may also send you postal mailings (newsletters/brochures/magazines). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local Ayvens entity via its webform for individual rights or use the contact details below. Which Personal Data do we process for this purpose? For this purpose, we may process your name and your business contact details. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.7.2 AYVENS PREMISES **4.7.2.a Access to and security control of Ayvens premises** What does this purpose entail? We may process your Personal Data when you visit us on our premises for the purpose of ensuring appropriate access controls and security, for which we have a legitimate interest (safety and security of our assets). Which Personal Data do we process for this purpose? For this purpose, we may process your name, your contact information and the person you are visiting. We may also process video and/or audio information about you through video/audio recording equipment, such as for instance CCTV. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.4.7.3 SUPPLIER REPORTING **4.7.3.a Fleet reporting tool** What does this purpose entail? We provide a designated fleet reporting tool. Suppliers’ contact persons can log onto these tools to review the status of their fleet, and to use other fleet reporting functionalities, such as dashboard reporting, trend analysis reporting, vehicle mileage and end of lease term. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of the agreement that we have with the Supplier). Which Personal Data do we process for this purpose? For this purpose, we process contact details and job function of Suppliers’ contact persons and login details (e.g., username and password). With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. 4.7.4 AYVENS BUSINESS PURPOSES **4.7.4.a Management reporting** What does this purpose entail? We process Personal Data for various Ayvens business-related purposes based on your consent or for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies, based on your consent. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. Which Personal Data do we process for this purpose? For this purpose, we may process your name, your e-mail address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. With whom do we share your Personal Data? See section 5 ‘WHO HAS ACCESS TO YOUR DATA?’. **4.7.4.b Compliance with laws and legal obligations and protection of Ayvens assets and interests.** What does this purpose entail? To comply with a legal obligation or where we have a legitimate interest, we process your Personal Data as appropriate or necessary: (a)Under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence (CDD), money laundering, financing of terrorism and other crimes); (b)to comply with legal process; (c)to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d)to enforce our terms and conditions and other applicable policies; (e)to protect our operations; (f)to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g)to allow us to pursue available remedies or limit the damages that we may sustain. Which Personal Data do we process for this purpose? For this purpose, we process the name, contact information, the date, place and country of birth of the ultimate beneficial owner of the counterparty that Ayvens wants to do business with; we also process the name, address, job title, signature and the date, place and country of birth of the person(s) who represent the counterparty towards Ayvens; your correspondence with Ayvens, the services you render and any other information mentioned in this Statement, if such is required for one of the purposes mentioned in the previous paragraph. For counterparty due diligence (CDD) purposes we periodically also process investigation data based on sanctions, enforcement, adverse media, politically exposed persons and anti-slavery screening. For this purpose, a risk-based approach is used to ensure only necessary Personal Data is collected. Please note, multiple (trained) employees are involved to evaluate the screening results in case of a ‘hit’ (human intervention). With whom do we share your Personal Data? Only if we are required to do so by law or sectorial recommendation to which Ayvens is subject, your Personal Data will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section 5 ‘WHO HAS ACCESS TO YOUR DATA?’.5. WHO HAS ACCESS TO YOUR DATA?
In addition to what is indicated for each purpose above regarding who has access to Personal Data under the control of Ayvens, we may also share Personal Data:
-Within the Ayvens group for the purposes described in this Privacy Statement. For a list of the Ayvens affiliates and their locations, that jointly process and use Personal Data, see this website.
-Within Société Générale Group to which Ayvens belongs, for internal administrative purposes, to fulfil a legal obligation, to improve our services, to enable us to comply more efficiently and more effectively with laws and regulations or for monitoring, control and reporting purposes. Reporting purposes relate to any regulatory and statutory reporting obligations and data requests as required by Société Générale Group’s regulators.
-To our third-party service partners, service providers and unaffiliated partners, or business partners such as original equipment manufacturers (OEMs) and brokers, to facilitate services they provide to you and us.
In order to provide you with our services, we often work closely with service partners, service providers and unaffiliated partners. Our independent service partners assist us in providing our leasing and other services to you, and include dealerships, maintenance providers, body repair shops, and roadside assistance providers, but also rental service companies and the administrators of our driver safety programs. Dealerships or suppliers of (electric) vehicles may require contact details of a driver to activate a personal account necessary to be set up as a driver, otherwise the vehicle does not work.
Service providers are companies we retain that support us in running our business, for example to help us maintain our IT network and related infrastructure and security and access controls to our premises.
We also use and disclose your Personal Data as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
-To comply with applicable law and regulations. This can include laws outside your country of residence.
-To cooperate with public and government authorities. To respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
-To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information, we believe is important.
-For other legal reasons. To enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
-In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Ayvens business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
We will limit access to Personal Data to personnel with a business need to know for the purposes described in this Statement.
4.8 DATA PERTAINING TO BUSINESS PARTNERS
6. WHY PERSONAL DATA MAY BE TRANSFERRED TO THIRD COUNTRIES?
Ayvens is a global service provider that has customers and locations around the globe. Your Personal Data may be stored and/or processed in a country other than the one you reside in. For a list of the Ayvens affiliates and their locations, that jointly process and use Personal Data, see the language sign on the top right of this website.
Some of the non-EEA countries are considered to provide for an adequate level of protection of your Personal Data, according to EU standards. You can find a list of these ‘adequate countries’ here. For the transfer of Personal Data to other countries, Ayvens has put in place adequate measures to protect your Personal Data, such as Standard Contractual Clauses. You may obtain a copy of these measures by contacting us using the address in the ‘How can you contact us?’ section below or by following this link.
7. CHILDREN’S PRIVACY
Our Services are not directed at individuals under the age of 18.
8. DO WE USE YOUR DATA FOR OTHER PURPOSES?
We may also use your Personal Data for a purpose other than the initial purpose. This is subject to the condition that the secondary purpose is in line with the initial purpose. The following factors are inter alia taken into account: are the purposes clearly related; is the secondary purpose appropriate and/or expected, was the Personal Data obtained directly from you or in another way; what kind of Personal Data is concerned for the secondary purpose; what would be the implications for you; and what data protection measures are applied when using your data for the secondary purposes.
9. HOW LONG WILL WE KEEP YOUR DATA?
Personal data of data subjects will be kept for the period necessary to fulfil the purposes described in this Statement unless a longer retention period is required or permitted by law.
The criteria applied to determine the applicable retention periods are: the duration of a relationship and provide the Services to you (for example, for as long as you use or lease an Ayvens vehicle); as required by a legal obligation to which we are subject; and as advisable in light of our legal position, such as in regard of applicable statutes of limitations, litigation or regulatory investigations. After the relevant retention period, Ayvens will either anonymize or purge your Personal Data.
The same principles to determine retention periods apply in relation to your personal data processed based on your consent, unless you withdraw your consent at an earlier point in time.
10. HOW DO WE SECURE YOUR DATA?
We seek to use appropriate organizational, technical and administrative measures to protect Personal Data within our organization, in accordance with applicable privacy and data protection laws and regulations. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us in accordance with the ‘How can you contact us?’ section below immediately.
11. CHANGES TO THIS STATEMENT
We reserve the right to amend this Statement at any time in order to, for instance, address future developments of Ayvens or changes in industry or legal trends. The ‘Last Updated’ legend at the top of this Statement indicates when this Statement was last revised.
12. HOW CAN YOU CONTACT US?
If you have questions, requests or complaints, please feel free to contact us via the contact page of the relevant Ayvens entity or contact our Data Protection Correspondent via this link. Because e-mail communication is not always secure, please do not include sensitive personal information in the e-mails you send us.
13. HOW CAN I EXERCISE MY PERSONAL DATA RIGHTS?
Please contact our Data Protection Correspondent via this link if you have any questions or concerns about how Ayvens processes your Personal Data; if you would like to exercise your right to request access, correct, delete Personal Data about you, restriction of processing or request that we cease using it (right to object), withdraw your consent or if you would like to request a copy or portability of your Personal Data. We will respond to your request consistent with applicable law.
Please note that we may not be required to comply (or fully comply) with your request. Applicable laws or regulations may impose conditions or restrict certain of such rights. For instance, for as long as we have a relationship with you, or where personal data is kept in a backup system (for the purpose of restoring the data in case of a data loss event) and the data purging cycle may be different than applicable to the production system. In those circumstances, we will write to you explaining why we are unable to comply at that moment or, in the case of backup data, the request may be implemented at a later stage (when the backup is overwritten).
In your request, please make clear what Personal Data you would like to access or have changed or deleted, or otherwise let us know what limitations you would like to put on our use of your Personal Data.
For your protection, in principle we only implement requests with respect to the information associated with the particular e-mail address that you use to send us your request, and we may request additional information necessary to verify your identity before implementing your request. Please note that certain Personal Data may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.
You may also lodge a complaint with a data protection authority for your country or region, or in the place of the alleged misconduct. Please see here a link to the national data protection authorities located in the European Union and the European Economic Area.