A. Privacy and security.
The protection of personal data and thus your privacy is taken very seriously by us.
We would like to take this opportunity to explain how we protect your data and what
it means for you when you use our personalizable services. In order to ensure the
greatest possible protection of your privacy, it is a matter of course for us that we
comply with all legal provisions on the subject of data protection.
B. Person in charge & data protection officer.
The responsible party and service provider is Allane Mobility Consulting GmbH, Dr.-Carl-von-Linde-Straße 2,
DE 82049 Pullach (hereinafter referred to as "AMC", "us" or "we").
You can reach AMC´s Privacy Officer at [email protected]
C. What is personal data?
Personal data is information that identifies you, such as your name, or information
that makes you identifiable, such as your address, telephone number, or even the IP
address used to identify computers on the Internet.
As a matter of principle, personal data is only collected and used by us to the extent
that this is necessary in order to provide a functional and convenient website as well
as our content and services. For various services, it is also necessary that you
provide us with certain personal data of your own accord (e.g. when using the
contact form, sending e-mails or sending vehicle enquiries) and that these are
processed by us.
Your data is always processed on the basis of the relevant statutory provisions.
If you would like more information about the processing of your data, the legal basis
of the processing, the purpose of the processing, the storage period or deletion
period and your data subject rights, please read the following explanations.
D. Categories of personal data.
We process the following categories of personal data in connection with our business
activities:
Master data: This includes, for example, your first name, last name, gender,
date of birth, address (private and/or business), your username for the online
account, a password of your choice and your customer number.
Communication data: These are telephone numbers that you provide to us
(including mobile phone numbers), fax numbers if applicable, your e-mail
address (private and/or business), third-party communication data if
applicable as well as communication content (e.g. e-mails) and IP address if
applicable.
Contract data: The contract data includes all data of the vehicle leased by you
(e.g. type, equipment, vehicle identification number, registration number) and
of the leasing contract concluded with you (start of contract, contract number,
conditions, end of contract).
Financial Data: The financial data we process is your bank account number(s)
that you have provided to us as part of the performance of the leasing
contract concluded with you, information that you have provided to us as part
of the self-disclosure process, and information about your creditworthiness
(e.g. based on Schufa inquiries).
Voluntary information: If you voluntarily provide us with information that is
related to the processing purposes described below, we will also process this
data.
E. Legal bases of the processing.
Article 6 (1) sentence 1 a) of the General Data Protection Regulation (GDPR):
According to this regulation, the processing of personal data is permissible if you
have given your consent to the processing.
Art. 6 para. 1 sentence 1 lit. b) GDPR: According to this provision, the processing of
personal data is lawful if it is necessary for the performance of a contract to which
you are a party or for the implementation of pre-contractual measures (e.g. requests
for the conclusion of a leasing contract), which are carried out at your request.
Art. 6 para. 1 p. 1 lit. c) GDPR: According to this provision, data processing is lawful if
it is necessary for compliance with a legal obligation to which we are subject.
Art. 6 para. 1 sentence 1 lit. f) GDPR: According to this provision, the processing of
personal data is lawful if it is necessary to protect the legitimate interests of the
controller, i.e. Allane Mobility Consulting GmbH, or of a third-party, unless the interests or fundamental
rights and freedoms of the data subjects, i.e. you, override these interests.
F. Purposes of the processing of personal data by AMC.
1. Conclusion and performance of contracts
If you conclude a contract with us (e.g. a leasing contract), we process the personal
data from you that is required for the performance of the respective contract. This
includes the contract data, the master data, your communication data and,
depending on the type of contract, your financial data as well as any voluntary
information. In connection with the performance of the contract, we also use this
data for customer support, e.g. in the event of queries on your part or ours regarding
the content of the contract.
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
2. Credit assessment and risk analysis
For the purpose of reducing the risk of non-payment, a credit check is carried out
prior to the conclusion of a leasing contract if the lessee is a consumer. We
transmit personal data collected for the conclusion of the leasing contract to
SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden ("SCHUFA"). This
involves information on the application, execution and termination of the
contractual relationship and, if applicable, data on conduct not in accordance
with the contract or fraudulent conduct.
The legal basis for these transfers is Article 6 (1) sentence 1 lit. b) and Article 6
(1) sentence 1 lit. f) GDPR. Our legitimate interest in processing your personal
data for credit assessment is that we need to protect ourselves against payment
defaults.
SCHUFA processes the data received and also uses it for the purpose of profiling
(scoring) in order to provide its own contractual partners in the European
Economic Area and in Switzerland and, if applicable, other third countries
(insofar as there is an adequacy decision on these by the European Commission)
with information on, among other things, the assessment of the creditworthiness
of natural persons. Further information on SCHUFA's activities can be found
online at www.schufa.de/datenschutz.
3. Customer service
In connection with the performance of the contract, we also use your data, which we
process within the framework of the performance of the contract, for customer
service, e.g. in the event of queries on your part or ours regarding the content of the
contract. As part of our customer service, we also use master data to send you
congratulations by post on your birthday or similar occasions.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b) GDPR, insofar as the
customer service is necessary for the fulfilment of our contractual obligations.
Furthermore, the legal basis for this processing is Art. 6 para. 1 p. 1 lit. f) GDPR,
because it is in our legitimate interest to ensure customer satisfaction.
4. Provision of replacement vehicle
If you require a replacement vehicle for a leased vehicle, we process your master
data and your communication data in order to provide you with a replacement
vehicle.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
5. Fuel cards/mineral oil companies
If you have ordered service or fuel cards from us, we process your master data and
your contract data.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
6. Breakdown service provider
We offer you roadside assistance as part of our customer service. In this context, we
process your master data, your communication data and your contract data.
The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
7. Tyre service
We also offer you the option of using tyre services via our cooperation partners (e.g.
summer/winter tyre exchange). In this context, we process your master data, your
communication data and your contract data.
The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
8. Insurances
In the case of new registrations, we process your master data, your communication
and contract data so that your leased vehicle is insured to the extent required by
law. This is done either by us arranging insurance for you or by you instructing us to
conclude an insurance contract for you.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
9. Maintenance services and repairs at partner workshops
Within the framework of the contract concluded with you, you can contact our
hotline to have a repair or maintenance carried out at our partner workshops. If you
wish to have such a repair or maintenance carried out, our hotline will name suitable
partner workshops for you. For the purpose of carrying out such maintenance or
repairs and for the preparation of an individual cost estimate, we process your
master data, your communication data and the contract data. In these cases, the
workshop settles with us. We also process your financial data in connection with the
onward charging of the repair costs to you.
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
10. Workshops
If you would like to have a repair and maintenance carried out yourself and contact a
workshop directly for this purpose, this workshop will transmit your master data,
your communication data and your contract data to us for the purpose of invoicing
the workshop.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
11. Experts
At the end of the leasing contract concluded with you and in the event that your
leased vehicle has bodywork and paintwork damage or that repairs are due as a
result of damage, we commission external assessors to check any defects, damage
or necessary repairs. For this purpose, we process your contract, master and
communication data so that the experts can carry out the inspection.
The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
12. Collection agency
If it is necessary and you are in arrears with leasing instalments or do not pay them,
we will pass on your master data, the contract data as well as the invoice data and
the reason for collection to collection agencies for the purpose of debt collection.
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f) GDPR. Our
legitimate interest in passing on the aforementioned data to a collection agency is to
enforce our contractually justified claims.
13. Contact forms, telephone as well as e-mail and postal
inquiries/contact
If you have questions about our services and products or regarding certain situations
(e.g. notification of a claim), you can contact us either by post, by telephone or via
our website. In these cases, you provide us with certain data or, in the case of
transmission by e-mail or contact form, enter this data in an input mask provided for
this purpose, via which your data is transmitted to us and stored. We use this data to
contact you or to be able to assign and process your request as quickly as possible.
The inquiries can be pre-contractual inquiries as well as in connection with an
already concluded contract. Depending on the circumstances, we process your
master data and your communication data. If you have already concluded a contract
with us, we also process your contract data and, if applicable, financial data and
voluntary information that you have provided to us in the case of enquiries about the
contract.
The legal basis for this processing is Art. 6 (1) p. 1 lit. b) GDPR in the form of pre-
contractual processing in response to your enquiry or processing for the purpose of
fulfilling a contract.
14. Processing operations for advertising purposes
14.1 Newsletter service
Before sending our newsletter, we obtain your express consent in the so-called
double opt-in procedure, i.e. we will only send you a newsletter by e-mail if you have
previously expressly agreed that we may send you newsletters by e-mail and you
have confirmed the correctness of the e-mail address you have provided.
If you do not confirm the newsletter order within 30 days, your data will be blocked
for the newsletter service and automatically deleted after one month.
We store your e-mail and IP address and the date of registration and confirmation
during this process. The purpose of this procedure is to prove your registration and,
if necessary, to clarify a possible misuse of your personal data.
For the receipt of the newsletter, only the processing of your e-mail address is
mandatory. The entry of further data, marked separately as optional, is voluntary
and serves the personal address. After your confirmation, we store the data you
have provided, in particular the e-mail address, for sending the newsletter.
The legal basis for data processing is Art. 6 para. 1 lit. a) GDPR (explicit consent).
If you have again expressly consented, we evaluate the way in which you use the
newsletter for the purpose of optimizing the newsletter and addressing the
subscribers. For this evaluation, the emails sent contain so-called web beacons or
tracking pixels, which are single-pixel image files stored on our website. For the
evaluations, we link the data we process and the web beacons with your e-mail
address and an individual ID. With the data obtained, we create a user profile in
order to adapt the newsletter to your individual interests. We can thus determine
whether and when you read our newsletters, which links you have clicked on and
derive personal user interests from this. The data is processed by our contractual
partner Inxmail GmbH and linked to the actions you have taken on our website.
Tracking is not possible if you have deactivated the display of images in your email
program by default. In this case, the newsletter will not be fully displayed and you
may not be able to use all the features. If you display the images manually, the
above tracking will be performed.
14.2 Customer product information and recommendations by e-
mail
As a customer of AMC, you will periodically receive product information and
recommendations from us via email about our own similar goods or services to those
you have already purchased. You will receive this product information and
recommendations from us regardless of whether you have subscribed to a
newsletter. In this way, we want to send you information about products from our
range that may be of interest to you based on your recent purchases from us. In
doing so, we strictly comply with the legal requirements.
We process your e-mail address as well as data for personal addressing.
The legal basis for the processing is Art. 6 para. 1 lit. f) GDPR (legitimate interest) in
conjunction with § 7 para. 3 UWG. Our legitimate interest is that the promotional
messages are related to contractual relationships (self-promotion for existing
customers) and we therefore want to inform you about our products or services.
You can object to receiving this product information and recommendations
by e-mail at any time. The objection does not cause higher costs than those
according to the basic rates (e.g. of your Internet access). Please send your
objection to [email protected] Upon your objection, we will
immediately stop sending the product information and recommendations
by e-mail.
14.3 Customer satisfaction surveys
At regular intervals, we conduct customer satisfaction surveys by e-mail or
telephone for the purpose of analysing and optimising our processes. However, this
is only done if you have previously given your express consent to be contacted by
telephone or e-mail for this purpose or if the requirements of Section 7 (3) UWG are
met.
If you have consented to this, we will also send you rating invitations by e-mail to
advertise our services for public display on Google, Trustpilot (https://de.trustpilot.com) and
Trusted Shops.
When you submit a review to Google, Google Ireland Limited, Gordon House, Barrow
Street, Dublin 4, Ireland, may collect personal data from you. Details can be found in
Google's privacy policy at https://policies.google.com/privacy?hl=de#products. The
same applies to Trustpilot A/S, Pilestraede 58, 5th Floor, 1112 Copenhagen K,
Denmark, whose privacy policy can be found at
https://de.legal.trustpilot.com/for-reviewers/end-user-privacy-terms, and Momentive Europe UC (Surveymonkey) 2nd
Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland, whose privacy policy
can be found at https://www.surveymonkey.de/mp/legal/privacy/.
The legal basis for this data processing is Art. 6 Para. 1 S. 1 lit. a) GDPR, if applicable
§ 7 Para. 3 UWG.
14.4 Submission of offers by telephone or e-mail
Provided that you have given your express prior consent, we will make you our own
additional offers by telephone that may be of interest to you, as well as
corresponding offers from our cooperation partners by telephone or e-mail. As far as
our own offers that we submit to you by e-mail are concerned, we refer to → Section
14.2 (Customer product information and recommendations by e-mail).
Within the scope of telephone or e-mail advertising, we submit our own offers as well
as offers from Group and subsidiary companies on the topics of vehicle sales
(new/used), vehicle leasing, vehicle financing and the purchase of used vehicles. In
addition, we will inform you about additional products that we offer or arrange for
you ourselves (e.g. loans, vehicle insurance, services, including TGH sales, vehicle
parts and accessories).
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. a) GDPR.
14.5 Conduct of lotteries
If you register for competitions organised by us, we will use the data you provided
during registration for the purpose of implementing the participation agreement
concluded between you and us, specifically for prize notification and, if applicable,
advertising for our offers and/or, if you have consented, offers from our competition
partners. You can find the conditions of participation in the respective competition.
The legal basis for this data processing is Article 6 (1) sentence 1 lit. a) GDPR, Article
6 (1) sentence 1 lit. b) GDPR and Article 6 (1) sentence 1 lit. f) GDPR, whereby it is in
our legitimate interests to use your data, which you have provided to us as part of a
competition, for advertising purposes.
15. Enrichment with further data
We also use the data available to us about you in order to provide you with offers
that may be tailored to you personally. In doing so, we process the data that we
have collected in the context of the contractual relationships that exist with you as
well as the data that you have voluntarily provided to us (e.g. positive/negative
experiences, wishes, the use of our website, etc.). In addition, we use the data we
hold about you for the purposes of risk analysis (see also → 2. Credit assessment and
risk analyses) and to evaluate the success of projects and campaigns.
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f) GDPR, because it is
in our legitimate interest to process your data in order to send you personalised
offers or to assess the risks of, for example, payment defaults.
The use of your personal data stored by third-parties, including our group companies
and subsidiaries, for the purpose of creating personalised advertising will only take
place if you have expressly consented to this in advance. This also applies to the
transfer of your data to third-parties for advertising purposes. The legal basis for
such data processing is Art. 6 para. 1 p. 1 lit. a) GDPR.
Excluded from this is the reference or disclosure of your master data such as name,
address, title, profession or date of birth for the purpose of advertising. This data
processing is justified by Art. 6 para. 1 p. 1 lit. f) GDPR (legitimate interests).
In addition, we use the data in pseudonymised or anonymised form to carry out
competitive or market analyses and for predictions using artificial intelligence (AI).
The legal basis for this data processing is Art. 6 para. 1 p. 1 lit. f) GDPR.
16. Digital signature
We offer you the possibility to sign documents electronically via an online service.
The provider and operator of this service is DocuSign GmbH, Neue Rothofstraße 13-
19, 60313 Frankfurt am Main, which acts on behalf of AMC. We have concluded
a corresponding contract on order processing with DocuSign GmbH. With the help of
DocuSign you can sign documents electronically in a legally secure and evidential
manner.
In connection with the digital signature, the personal data listed in the documents to
be signed are processed. These are in particular your master data, your
communication data as well as financial data in the form of your bank details. In
addition, computer-generated data is processed, namely the IP address, the date,
the time and the amount of data transferred, the internet service provider as well as
the HTTP status code, the browser version and language and the operating system
version.
The legal basis for the processing is Art. 6 para. 1 lit. b) DS-GVO.
The service provider DocuSign stores your data for a further 14 days after the
signature has been provided before it is permanently deleted. The data required for
the history is stored for a further 180 days, after which it is permanently deleted.
You can view the data protection information of DocuSign GmbH via the following
link: https://www.docusign.de/unternehmen/datenschutz.
17. Identification via IDnow
In order to conclude a leasing contract with us, it is necessary that you identify
yourself to us in a legally secure manner. Legally secure identification is also
required by law, e.g. under the Money Laundering Act. For this purpose, we work
together with the service provider IDnow GmbH, Auenstraße 100, 80469 Munich
("IDnow"). IDnow offers the possibility for you to identify yourself via the IDnow
app or via a website. IDnow carries out a verification process through a video
identification procedure and has your electronic signature created by a partner
company, DocuSign France SAS, 175 Rue Jean Jacques Rousseau, 92130 Issy-les-
Moulineaux, France ("DocuSign").
You can carry out the video identification procedure either through the IDnow app
or via a secure IDnow website. If you use the IDnow app, you have the option of
activating a biometric identifier, depending on your terminal device, via your
fingerprint or facial recognition for the login to the customer area when you log in
for the first time. You can deactivate this login by biometric identification at any
time. The data processing for biometric identification depends on your mobile
device. We do not receive any data from you and are not responsible for the
procedure.
If you opt for the video identification procedure via the IDnow app, the IDnow app
accesses the camera and microphone of your mobile device with your consent. In
doing so, it is also necessary to access the device memory and the camera light
of your mobile device. The latter is necessary to make the holograms on your ID
document more visible as part of the identification procedures. Access to the
device memory is necessary to enable downloading on your mobile device when
retrieving documents. Neither we nor IDnow will process the data and images you
have stored on your mobile device. If you decide to carry out the identification
procedure via the IDnow website, the necessary video and sound files must be
transmitted via a secure Internet connection. In this case, IDnow also accesses
the camera and microphone of your computer with your consent.
In order to participate in the IDnow video identification process, you must first
provide your personal data such as your surname, first name, address, date of
birth, email address and mobile number. To carry out the video identification
process, IDnow will send you an identification number, the receipt of which you
must confirm to IDnow, either via the app or a secure IDnow website. The
identification process requires a valid official ID document with a photograph, of
which IDnow will take photographs and video footage. In addition to these
images, IDnow captures all data contained on the ID document. In order to
perform the comparison with your ID document, IDnow completes photo and
video recordings of you via a video chat conducted by an IDnow employee. The
chat is also recorded acoustically.
For the subsequent electronic signature, IDnow transmits your name, your mobile
phone number and the contract documents required for the conclusion of your
loan agreement to DocuSign. You must confirm the accuracy of your data
transmitted to DocuSign and declare your consent to this data being transmitted
to the contractual partners involved as part of the certificate used for signing. The
signature takes place via an identification code sent to you via SMS and your final
confirmation.
The legal basis for data processing is your consent (Art. 6 para. 1 sentence 1 lit. a
DSVO) as well as the implementation of pre-contractual measures for the
conclusion of your loan agreement (Art. 6 para. 1 sentence 1 lit. b GDPR). In
addition, the identification is required by law. The legal basis for the processing is
therefore also Art. 6 para. 1 p. 1 lit. c GDPR.
For information on data processing by IDnow and DocuSign, please refer to the
IDnow data protection declaration and our DocuSign data protection
declaration.
We store the data collected as part of the video identification procedure and the
creation of the electronic signature as a so-called evidence file in accordance with
the Money Laundering Act for a maximum period of five years. After this period,
the data will be deleted, unless other legal regulations stipulate a longer retention
period. All other data collected in connection with the video identification
procedure, such as the IdentID, the mobile phone number or the identification
code, will be deleted by IDnow according to our instructions after successful
completion of the ID procedure by IDnow and DocuSign.
18. Trusted shops reviews on sixt-neuwagen.de
18.1 Evaluation invitations on sixt-neuwagen.de
You have the possibility to click on a rating link of Trusted Shops at the end of an
order process on sixt-neuwagen.de. In this case your e-mail address and the
transaction number will be transferred to Trusted Shops in order to pre-fill the rating
form.
The legal basis for this processing is Art. 6 (1) sentence 1 lit. f GDPR. Our and
Trusted Shops' legitimate interests are the provision of the transactional evaluation
services linked to the specific order and the avoidance of input errors.
If you do not submit the evaluation form afterwards, the transmitted data will be
automatically deleted and otherwise used by Trusted Shops exclusively for the
processing of the contract on the use of the evaluation system.
18.2 Shared responsibility
Trusted Shops GmbH, Subbelrather Str. 15c, 50823 Cologne, and we are jointly
responsible for parts of the above processing. This concerns the sending of rating
invitations. In contrast, the responsibility under data protection law for obtaining
your consent to send you rating reminders by e-mail is ours alone, while Trusted
Shops GmbH is solely responsible for the operation of the rating platform and for the
content and associated data processing of the widgets. The data protection
declaration of Trusted Shops GmbH is available at
https://www.trustedshops.com/tsdocument/BUYER_AUTO_PROTECTION_TERMS_de.pd
f. Due to the partly joint responsibility for data processing, Trusted Shops GmbH and
we have concluded a contract in accordance with Art. 26 (1) GDPR. The main
provisions of this contract stipulate that we transmit the data required for the
submission of ratings to Trusted Shops via
www.sixt-neuwagen.de and obtain the
consent required for the rating reminders by e-mail.
If you wish to assert your rights in accordance with the Data Protection Regulation
(see below → M. Your rights in relation to the processing of personal data) or have
other data protection questions in connection with the services of Trusted Shops,
please contact Trusted Shops GmbH at the above address or the contact details
given in the data protection information linked above as part of the joint
responsibility between us and Trusted Shops. Independently of this, you can also
assert your rights against us. If necessary, we will forward your request to the other
responsible party, Trusted Shops.
19. Processing operations in connection with the use of our
website
19.1 Log files
Every time you visit our website, our system automatically collects data and
information from your computer system and stores it in so-called log files on the web
server and in our system. This is necessary so that you can use our website at all.
Data is also collected for the purpose of protecting our website from unauthorized
access or for the purpose of tracking unauthorized access. Specifically, the following
data is processed:
- Date and time of access/web page view
- IP address of the requesting computer
- URL of the website
- URL of the website from which the user came to the page (http referrer)
- Information about the browser type or version (UserAgent)
- Http status code
- Length of the content
- Duration of the processing of the http access
The aforementioned data is not stored together with other personal data.
The legal basis for the processing, insofar as personal data are concerned, is Art. 6
para. 1 p. 1 lit. f) GDPR. Our legitimate interest lies in the fact that we hereby need
to ensure and improve the functionality of our website and secure our IT systems
against unauthorized access.
19.2 Cookies and similar technologies
Our website may use cookies and similar technologies. Cookies are small text files
that are copied from a web server to your terminal device and assigned to the
browser you are using. Cookies do not execute any programs and do not leave any
viruses on your computer. For more information on cookies and how to disable them,
please refer to the Cookie Policy.
The legal basis for the setting of cookies is either Art. 6 para. 1 p. 1 lit. a) GDPR,
insofar as cookies are set that process personal data (the IP address) and for which
consent is required pursuant to Section 25 para. 1 TTDSG in conjunction with Art. 4
No. 11 GDPR. Art. 4 No. 11 GDPR is required, or Art. 6 para. 1 p. 1 lit. f) GDPR in
conjunction with. § Section 25 (2) No. 2 TTDSG, for cookies that are absolutely
necessary so that we can provide a service requested by you, provided that personal
processing takes place.
20. Voice recordings for quality control
In order to improve and optimize our customer service, we randomly record calls to
our service hotline. This only happens with your express prior consent (consent).
Before we start the voice recording, you will be explicitly asked whether you want to
consent to this. Your consent is always limited to the specific telephone call. If you
do not wish to have a voice recording, it will not be made.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. a) GDPR.
G. Social media.
1. Use of YouTube
We integrate videos of the internet platform YouTube of the provider Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland. These videos are integrated
with the "extended data protection mode" function. According to the provider, this
has the effect that no information about the visitors is stored on the website unless
they watch the video. In this case, Google collects information about the user
behavior. Furthermore, YouTube assigns the connection information to your YouTube
account, provided that you are logged into YouTube as a user at the same time. If
you do not agree to this, you must either log out of your YouTube user account
before visiting our website or adjust the corresponding settings in your YouTube
account.
You can find further information on data protection at YouTube in the data protection
declaration of the provider Google: https://policies.google.com/privacy.
2. Facebook
AMC uses plugins from the social network facebook.com, which is operated by
Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). This
includes communication tools of the social network Facebook, which are used on this
website. For details, please refer to the Cookie Policy.
The legal basis for this processing is Art. 6 para. 1 p. 1 lit. a) GDPR.
3. Use of Google Maps
Autohaus24 GmbH (www.autohaus24.de) uses Google Maps API applications. Google
Maps is a service provided by Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland. The Google Maps API applications are essential for the provision of
the service. Google's privacy policy can be found at:
https://policies.google.com/privacy. Google's terms of use, including for Google
Maps, can be found at: https://policies.google.com/terms?gl=DE&hl=de.
The use of Google Maps is based on Art. 6 para. 1 p. 1 lit. f) GDPR, as it allows us to
better inform you of our locations. The use of Google Maps serves to show customers
the appropriate map of the surroundings as well as the nearest stations. The
transmission of all location data to Google is anonymised; no further information is
passed on to Google.
H. Other websites with login function.
1. Sale of the GHG quota of electric vehicles via the partner portal
www.elektrovorteil.de
You can register with our partner portal www.elektrovorteil.de on our website
www.sixt-neuwagen.de to market the GHG quota to be generated for your electric
vehicle. To use the services of www.elektrovorteil.de, enter the following data in the
input field on our website at www.sixt-neuwagen.de:
First name
Last name
E-mail address
Postal address
Payment data (account holder, IBAN)
Vehicle registration data, in particular:
A = Official registration number
B = date of first registration, 2.1 = code to 2, 2.2 = code to D.2 with check
digit
J = vehicle category
E = vehicle identification number, 3 = check digit of the vehicle identification
number
D.1 = Make, D.2 = Type/variant/version, D.3 = Commercial description
2 = Manufacturer's abbreviation
5 = Vehicle category and bodywork designation
P.3 = Fuel type or energy source
10 = Code for P.3
22 = Remarks and exceptions
Upon completion of registration, www.elektrovorteil.de collects this data directly. The
legal basis here is Art. 6 para. 1 lit. b) GDPR. The responsible party for your personal
data at www.elektrovorteil.de is Ecoturn GmbH, Ludwig-Thoma-Straße 41, 82031
Grünwald. The data protection provisions of
www.elektrovorteil.de, which apply to the processing of data by
www.elektrovorteil.de, can be found at https://elektrovorteil.de/data-protection.
When offering to market the GHG quota for your electric vehicle, we work closely
with Ecoturn GmbH. This also concerns the processing of your personal data. Ecoturn
GmbH and we have jointly determined the process of registration and the purposes
of data processing in the context of marketing the GHG quota for your electric
vehicle. Ecoturn GmbH and we are therefore also jointly responsible for this data
processing. For this reason, we have concluded a corresponding contract pursuant to
Art. 26 (1) GDPR. The main provisions of this contract stipulate that we collect the
data required for the marketing of the GHG quota on www.sixt-neuwagen.de with the
above-mentioned registration and then transfer the data to www.elektrovorteil.de.
The further processing for the fulfilment of the contract concluded between you and
Ecoturn GmbH for the marketing of the GHG quota for your electric vehicle is the
responsibility of Ecoturn GmbH. If you wish to assert rights under the GDPR (see
below → M. Your rights in relation to the processing of personal data), Ecoturn GmbH
is responsible for this. However, you can also assert your rights against us. We will
then forward your request to Ecoturn GmbH without delay.
2. Customer portal functions on sixt-haendlerboerse.de
2.1 Registration
You can register on the website sixt-haendlerboerse.de. To do this, enter the
following data in an input field:
- Company name
- Address
- Phone number
- UID number
- Activity
You can also enter certain user data. After completing the registration, you submit
this data to us. Each buyer must register before participating in a sales event for the
first time. In doing so, each buyer must expressly declare and prove his
entrepreneurial status and his status as a motor vehicle dealer before being
admitted to submit offers for the first time. The type of proof is determined by the
seller. The registration confirmation shall be sent to the Buyer by e-mail and shall
contain the Buyer's initial password determined by the Seller. With the assigned
initial password and the assigned dealer ID/username, the Buyer can authenticate
himself in the system and assign his personal password. Only after changing the
initial password is it possible to participate in the sales event. The username is
visible to all participants in the screen display of the sales event, the name of the
buyer, however, remains anonymous, as does the password.
The legal basis of the processing is Art. 6 para. 1 p. 1 lit. b) GDPR, as registration
data must be processed in order to provide you with access to the sales portal.
2.2 Login function
You can log in to our Sixt dealer exchange website with your e-mail address and
password if you have registered beforehand.
The processing of your data here is based on Art. 6 para. 1 p. 1 lit. b) GDPR, as you
are entitled to log into the portal through the successful registration. We need the
data to be able to authenticate you successfully.
2.3 Forgotten password
If you have forgotten your portal password, you can request that a new password be
sent to you. To do this, you must provide your username and e-mail address for
authentication reasons, so that we can send you the new password to this e-mail
address.
The processing of your data is based here on Art. 6 para. 1 p. 1 lit. b) GDPR, since
you have a contractual right to access our portal and you can only offer your used
car through this.
3. Third-party websites
Our websites may contain links to and from partner websites. Please note that if you
click on the link to access a third-party website, they will publish their own privacy
policies and we do not accept any responsibility or liability for those policies.
I. Transfer to third countries
A transfer of your personal data to third countries does not take place. Any transfers
to a third country take place on the basis of an adequacy decision of the European
Commission. If there is no adequacy decision of the European Commission for the
respective third country, the transfer to a third country takes place on the basis of
appropriate guarantees within the meaning of Art. 46 (2) GDPR. Copies of these
guarantees can be requested from us at the above address (see → Responsible
party). Third countries are all countries outside the European Economic Area. The
European Economic Area includes all countries of the European Union as well as the
countries of the so-called European Free Trade Association, namely Norway, Iceland
and Liechtenstein.
J. Recipients or categories of recipients.
We use third-parties to fulfil our contractual and legal obligations and to fulfil our
legitimate interests. These include, for example, car dealers to whom we transfer
your data for the purpose of delivering the leased vehicles to you. We also pass on
your data to dealers and service providers for the purpose of fulfilling orders for
additional products such as winter tyres or the use of additional services such as
maintenance work.
Other service providers are those who, for example, register the leased vehicles with
the relevant authorities on our behalf, logistics companies or forwarding agents that
we commission for the purpose of delivery to you, or service providers who envelope
our postal items and make them ready for dispatch.
We have commissioned the company Inxmail GmbH, Wentzingerstraße 17, 79106
Freiburg im Breisgau, to send the newsletter (Newsletter Service).
Data via form inquiries under deal.sixt-neuwagen.de are collected on our behalf by
MCON Germany GmbH, Mettlacher Straße 5, 81579 Munich and transmitted to us.
We have concluded a corresponding contract on order processing with MCON
Germany GmbH.
In addition, we may transfer your personal data to other recipients for the purposes
stated under F., such as to authorities, e.g. in connection with the registration of
the vehicle leased by you, to workshops, fuel card service providers, petroleum
companies or to insurance companies.
As part of the credit check, we transmit your data to Schufa. If you wish to obtain
financing for a vehicle as part of our contractual relationship, we will forward the
information you have completed to banks that offer financing options for our
vehicles.
If a replacement vehicle is provided for a leased vehicle, we transmit your personal
data to our cooperation partners so that they can provide you with a suitable
replacement vehicle.
If the appraisal of your leased vehicle is necessary, we will pass on your personal
data to the appraisers commissioned by us for the purpose of fulfilling the appraisal
order.
If it is necessary and we have to enforce claims against you arising from the leasing
contract, we will transmit your personal data to collection agencies engaged by us.
In the event of legal disputes, whether to defend or enforce legal claims, we also
transmit data to lawyers, experts or courts.
If service providers process personal data on our behalf, we have concluded the
legally required contracts with them on commissioned processing pursuant to Art. 28
GDPR.
K. Duration of storage.
We store your personal data until the respective purpose on which the processing is
based has ceased to exist.
If we are legally obliged to store personal data, the data is stored for the duration of
the legal obligation. Depending on the legal obligation, this can be up to thirty years.
In addition, retention periods according to tax law (6 years according to § 146 of the
German Fiscal Code) and commercial law (10 years according to § 257 of the
German Commercial Code) may apply. If necessary, we will block your data for
ongoing operations during this period, provided that there is no other purpose for the
processing.
L. Profiling and automated processing.
An automated decision-making in the sense of Art. 22 GDPR does not take place.
However, we form profiles in such a way that we enrich the data available to us with
other data within the scope of what is legally permissible. For details and the
corresponding legal basis, please refer to the explanations under F: 15 "Enrichment
with other data".
M. Your rights in relation to the processing of personal data.
We would like to inform you about your rights regarding the processing of your
personal data. If you have any questions about your rights or wish to exercise your
rights against us, please contact our data protection officer at
datenschutz@mobility-consulting.com or by post to "Data Protection Officer at Allane Mobility Consulting GmbH, Dr.-Carl-von-Linde-
Straße 2, DE 82049 Pullach".
1. Revocation of your consent (Art. 7 para. 3 GDPR)
If you have given your express consent to the processing of your personal data, you
may revoke this consent at any time. The withdrawal of consent does not affect the
lawfulness of the processing carried out on the basis of the consent until the
withdrawal. You will be informed of this right of withdrawal before you give your
consent.
2. Right to information (Art. 15 GDPR)
You have the right to request confirmation from us as to whether we are processing
personal data about you. If this is the case, you have the right to be informed about
this personal data. If personal data is transferred to a third country or an
international organisation, you also have the right to be informed about adequate
safeguards to ensure that the recipients comply with the provisions of the GDPR.
3. Right of rectification (Art. 16 GDPR)
You may request us to rectify without delay any inaccurate data concerning you.
Taking into account the purposes of the processing, you also have the right to
request that incomplete personal data be completed, including by means of a
supplementary declaration.
4. Right to erasure or the "right to be forgotten" (Art. 17 GDPR)
You have the right to request the immediate deletion of your data if one of the
following reasons applies:
- Data are no longer necessary for the purposes for which they were collected or otherwise processed,
- You have withdrawn your consent and there is no other legal basis for the processing,
- You object to the processing pursuant to Article 21(2) sentence 1 GDPR on grounds relating to your particular situation and there are no compelling legitimate grounds for the processing,
- You object to processing for direct sales pursuant to Article 21(2) sentence 2 of the GDPR,
- the data have been processed unlawfully,
- the deletion of the data is necessary to comply with a legal obligation under European or German law,
- the data relating to an offer of information society services has been collected directly from a child, Art. 8(1) GDPR.
We will comply with the request for deletion unless we are legally obliged or entitled
to continue to store and process your data. Furthermore, we are entitled to further
storage if the assertion, exercise or defence of legal claims should not be possible
without your data.
5. Right to restriction of processing (Art. 18 GDPR)
According to Art. 18 GDPR, we may only process data in a restricted manner in the
following cases:
- You dispute the accuracy of your information until we can verify its accuracy,
- the processing is unlawful and you refuse to erase your data and instead request that the use of personal data be restricted,
- we no longer need the data for the purposes of processing, but you need them for the assertion, exercise or defence of legal claims, or
- you object to the processing pursuant to Article 21 (1) No. 2 GDPR on grounds relating to your particular situation, provided that it is not yet clear whether the legitimate grounds for processing by us override your interests.
To the extent that processing is restricted, we may only store such data. In this case,
further processing is only permitted with your consent or for the purpose of
asserting, exercising or defending legal claims or protecting the rights of another
natural or legal person or for reasons of important public interest of the Union or a
Member State. You may withdraw your consent in this regard at any time. You will be
notified by us before the restriction is lifted.
6. Obligation to notify (Art. 19 GDPR)
Please note that we are obliged to inform all recipients to whom your data has been
disclosed about a correction or deletion of your data or a restriction of processing.
This does not apply if such information would be impossible or would involve a
disproportionate effort.
We will inform you of these recipients if they so request.
7. Right to data portability (Art. 20 GDPR)
You have the right to receive the data concerning you that you have provided to us
in a structured, common and machine-readable format. You also have the right to
have us transfer this data to a third-party in certain cases. However, this right must
not affect the rights and freedoms of other persons, including our company. Insofar
as this is the case, we are entitled to refuse to hand over or transfer your data.
8. Right to object (Art. 21 GDPR)
If we process your data on the basis of a legitimate interest (Art. 6(1)(f) GDPR), you
have the right to object to this if the reasons for this arise from your particular
situation. This also applies to profiling based on these provisions.
In this case, we will no longer process your data unless we can demonstrate
compelling legitimate grounds for the processing. This must override your interests,
rights and freedoms, or the processing serves the assertion, exercise or defense of
legal claims.
If we process your data for the purpose of direct marketing, you may object to the
processing of the data. This also applies to profiling, insofar as it is connected with
such direct advertising.
After your objection, your data will no longer be processed for these purposes.
9. No contractual obligation
You are neither contractually nor legally obliged to provide us with your personal
data. However, we would like to point out that we cannot conclude any contracts
with you if you do not provide us with your data.
10. Right to complain to a supervisory authority (Art. 77 GDPR)
You have the right to lodge a complaint with a supervisory authority, in particular in
the Member State of your residence, workplace or the place of the alleged
infringement, if you consider that the processing of data concerning you infringes
the General Data Protection Regulation. This is without prejudice to any other
administrative or judicial remedies to which you may be entitled. The supervisory
authority responsible for us is the
Bayerische Landesamt für Datenschutzaufsicht
Postfach 1349
91504 Ansbach
www.lda.bayern.de
Security, SSL technology.
AMC has taken technical and organizational measures to protect your personal
data, in particular against accidental or intentional manipulation, loss, destruction or
access by unauthorized persons. These security measures are continuously adapted
in line with technological developments. The transmission of personal data between
your computer and our server is always encrypted (SSL procedure, Secure Socket
Layer).
Changes to the privacy notice.
We reserve the right to update this privacy notice regularly if the legal, technical or
economic framework changes. When we update our privacy notice, we will take
appropriate steps to inform you of the significance of the changes we have made, if
necessary.
Status: July 2022