According to the Act "personal information" means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, such as:

• information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
• information relating to the education, medical, financial, criminal or employment history of the person;
• any identifying number, symbol, e-mail address, physical address, telephone number or other particular assignment to the person;
• the biometric information of the person;
• the personal opinions, view or preferences of the person;
• correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that will reveal the contents of the original correspondence;
• the view or opinions of another individual about the person; and
• the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

We collect and process your personal information mainly to contact you for the purposes of understanding your requirements, and delivering services accordingly. For this purpose, we will collect contact details including your name and organisation.

We collect information directly from you where you provide us with your personal details. Where possible, we will inform you what information you are required to provide to us and what information is optional.

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

We will use your personal information only for the purposes for which it was collected and agreed with you. In addition, where necessary your information may be retained for legal or research purposes.

For example:

• To gather contact information;
• To confirm and verify your identity or to verify that you are an authorised user for security purposes;
• For the detection and prevention of fraud, crime, money laundering or other malpractice;
• To conduct market or customer satisfaction research or for statistical analysis;
• For audit and record keeping purposes;
• In connection with legal proceedings.

We undertake to keep your personal information for no longer than is necessary for the purposes for which we process them, in accordance with the regulations.

In order to calculate the retention period of your personal data, we use notably the following criteria:

• The duration of your contract, if you have entered into such contract with DEALERTRADE;
• The time required to proceed your request;
• The duration for which your user account is opened, unless you have been inactive for 3 years;
• Your reactivity to our marketing information;
• The need to keep a record of your interactions with us, for a good management of our commercial relationship;
• Our legal or regulatory obligations.

We may have to keep some of your personal data for a longer duration, in an archive file, in order for us to be able to defend in a legal action, until the end of the statute of limitation provided by applicable law.

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures cover:

• Physical security;
• Computer and network security;
• Access to personal information;
• Secure communications;
• Security in contracting out activities or functions;
• Retention and disposal of information;
• Acceptable usage of personal information;
• Governance and regulatory issues;
• Monitoring access and usage of private information;
• Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

You have the right to request a copy of the personal information we hold about you. To do this, simply contact us at the numbers/addresses as provided on our website and specify what information you require. We will need a copy of your ID document to confirm your identity before providing details of your personal information.

You have the right to ask us to update, correct or delete your personal information. We would appreciate it if you would keep your personal information accurate.

Please note that any such access request may be subject to a payment of a legally allowable fee.

We may automatically collect technical information about you when you visit any of our websites or use our mobile apps, including your IP address, your browser settings, using trackers (cookies).

For more information on this, please read our cookies policy.

We may modify from time to time this information document. When required or needed, we will inform your and / or request your consent. We therefore invite you to have a look at it at every visit to get the up-to-date version.

Version 01, updated on 15/02/2022