PRIVACY POLICY ALSENSE MOTORSPORT
ALSENSE MOTORSPORT (named herein “Alsense Motorsport” or the “Company”),
with its legal name Alsense Motorsport SRL is processing your personal data as
Data Controller for all personal data that your either share with us in the
process of acquiring a product or services that we offer, either just by
visiting our website, processing based on the Cookie policy and your consent.
DATA CATEGORIES
If you wish to purchase one of our products form our website, Alsense
Motorsport will request you to provide your Full name, e-mail address, phone
number, home / delivery address, postal code.
These data categories will be processed by Alsense Motorsport for the
purpose of identifying you as customer and the products that you ordered as
well as for shipping such products to the address indicated by you. The e-mail
address is requested and processed by Alsense Motorsport for the purpose of
contacting you with regard to the order placed for reasons derived from such
order.
Considering that the payment of the ordered products will be realized
through the support of our online payment provider, STRIPE Inc, will request
your payment details such as Credit / Debit Card number, Full name, date of
expiry for the Credit / Debit Card, CVC/
security number of the Credit/ Debit Card. These personal data will not be
processed by Alsense Motorsport in any way and Alsense Motorsport will not have
access to such data.
Besides the above listed data categories, while visiting Alsense
Motorsport website (https://www.alsense.eu/
), technical browsing data will be processed by Alsense Motorsport in order to
emphasize a qualitative content. This kind of data is generically named “cookie
data” or “cookies” and its processing by Alsense Motorsport is regulated under
the Cookie Policy.
DEFINITIONS
Data Subject – natural person whose personal data is being
processed
Data Controller – the natural or legal person, public
authority, agency or other body which, alone or jointly with others, determines
the purposes and means of the processing of personal data; where the purposes
and means of such processing are determined by Union or Member State law, the
controller or the specific criteria for its nomination may be provided for by
Union or Member State law
Data Processor – a natural or legal person, public authority,
agency or other body which processes personal data on behalf of the controller
GDPR – General Data Protection Regulation or EU
Regulation 679/ 2016 on the protection of natural persons with regard to the
processing of personal data and on the free movement of such data
Personal data – any information relating to an identified or
identifiable natural person (‘data subject’); an identifiable natural person is
one who can be identified, directly or indirectly, in particular by reference
to an identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that
natural person
Processing of Personal data – any operation or set of operations which is
performed on personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organisation, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction
PURPOSES OF PROCESSING
Considering Alsense Motorsport desire to offer its clients, customers
and partners, products and services at their best quality, such services and
goods cannot be granted unless the following personal data processing purposes
are pursued by the Company:
1.
Registration
of your online request in case you are contacting us for support or additional
information;
2.
Registration
and identification of the order, when you are placing such an order on our
website;
3.
Accounting.
Your personal data bill be processed for accounting purposes only if you placed
and order to Alsens Motorsport for the acquisition of a good or services
offered by the Company;
4.
Product
delivery after your order had been placed and the billing process performed;
5.
Providing advices
or consultancy upon your request
6.
Marketing
through newsletters in those cases in which you choose to receive such
newsletters from Alsense.
7.
Maintaining
communication relations with the you through social media environments, in
those cases in which you are contacting us through these environments.
LEGAL BASES
Alsense Motorsport
processes your personal data under different legal basis, depending on the
purposes of processing as described above. Thus, for a better understanding the
company will emphasize the legal basis in correlation with the above data
processing purposes:
Data Processing purpose |
Applicable legal basis for Alsense Motorsport |
1. |
Legitimate interest |
2. |
Processing is |
3. |
Legitimate interest |
4. |
Knowing the fact |
5. |
Legitimate interest |
6. |
Your consent. Thus, |
7. |
Legitimate interest |
RETENTION PERIOD
Alsense Motorsport
will process and store your persona data for as long as it is necessary for
achieving the above described purposes. Therefore, determining the exact period
of time for which your personal data will be processed by Alsense Motorsport is
strictly related to the purposes of processing and emphasized as such
hereunder:
Data Processing purpose |
Retention period |
1. Registration Data |
6 months from the |
2. Registration Data |
3 years from |
3. Accounting Data |
10 fiscal years |
4. Product Data |
3 years from the |
5. Providing Data |
6 months from the |
6. |
3 years from the |
7. |
Considering |
DATA RECIPIENTS
If you enter in contact with Alsense Motorsport or place an order for
one of the goods or services from our website, mining that you are entering
into a contract with the Company, the Company
will transfer your personal data to its hosting and e-mail provider
Bluehost Inc from Burlington, Massachusetts,
USA, owned by The Endurance
International Group, Inc. with its European representative AppMachine B.V., located at Sophialaan 32, 8911 AE Leeuwarden,
Nederland. Such transfer is
regulated under article 49 paragraph 1. b) “Derogations for specific
situations” of the EU Regulation 679/ 2016 on the protection of natural persons
with regard to the processing of personal data and on the free movement of such
data („GDPR”), legal provision that provides the possibility of a personal data
transfer to third countries outside of EU when „the transfer is necessary for
the performance of a contract between the data subject and the controller or
the implementation of pre-contractual measures taken at the data subject’s
request”. Such legal provisions are applicable in that particular case when you
are an EU citizen or resident and GDPR is applicable to you. Moreover, such
transfer is guarantee in terms of personal data protection by the Privacy
Shield ceritficate owned by Bluehost Inc. (https://www.privacyshield.gov/participant?id=a2zt00000004pu0AAA&status=Active
)
Besides the above listed data recipient and processor of Alsense
Motorsport, the Company will allow access to your personal data communicated to
us, to its accounting service provider, Contradiction SRL, located in Romania,
for the provision of accounting services that include processing of the
invoices that you receive after placing an order on the Company’s website.
For those of you who
requested to receive a newsletter form Alsense Motorsport, Alsense Motorsport
will process your e-mail address and provide it to MailChimp, owned by Rocket
Science Group LLC, a company headquartered in the State of Georgia in the
United States. Your personal data transfer to this US entity is being performed
under MailChimp Standard terms of
use which incorporates the EU Commission Standard Contractual Clauses, one
of the GDPR requested guarantees in case of personal data transfer outside EU.
Considering the fact that multiple
services shall be granted to Alsense Motorsport upon its business
requirements, your personal data might be transfered to additional services
providers that will act as Data Processors on behalf of Alsense Motorsport,
with the prior implementation of the applicable data protection requirements,
especially those emphasized by the GDPR.
In such cases Alsense Motorsport will document and instruct in writing
its Data Processors with regard to the protection of your personal data, in
compliance with GDPR and will conclude appropriate data protection clauses. If
such a processing activity will imply personal data transfer outside EU, to a
country not previously authorized by the EU Commission, the Company will
implement one of the necessary data transfer guarantees, among which could be listed the Standard Contractual
Clauses.
For these reasons, Alsense Motorsport reserves the right to update
without your consent the present Privacy Policiy, if one of the conditions or
processing situations or purposes will be modified in the meantime.
LOCATION OF PROCESSING
In general, you persona data will be processed in the European Union,
directly by Alsense Motorsport. For the accomplishment of those processing
activities that are listed in the above section, your personal data will be
processed in the US as well.
IMPLEMENTED TECHNICAL AND ORGANIZATIONAL
MEASURES
Alsense Motorsport
cares about your privacy and rights to privacy, this being the reason why the
Company implemented GDPR requirements by design and adopted all necessary data
protection and security measures to make sure that your personal data is
protected while processed by the Company. Therefore, Alsense Motorsport performed
privacy due diligence when selecting its hosting and e-mail provider,
designated a Data privacy Officer for establishing the necessary legal
requirements in order for your rights to be protected, implemented adequate
retention periods in order to ensure a limited data processing only to what is
necessary for achieving the above listed purposes, secured its website and
communication data in transit.
YOUR DATA PROTECTION RIGHTS UNDER GDPR
Right to be informed à you
have the right to be informed about the personal data processing operations
carried out by Alsense Motorsport.
Right to access your personal data à you have the right to access your personal
data processed by Alsense Motorsport. If we agree, depending on the applicable
legal provisions, that we are obliged to provide you with your personal data,
we will provide you such information for free. Before Alsense Motorsport will
provide personal data to you, we may request proof of your identity and
sufficient information about your interaction with the Company so that we can
find your personal data.
Right to rectification/ right to intervene à If the information which the Company holds
about you is incorrect, you have the right to ask us to correct any inaccuracy
in terms of personal data.
Right to Erasure/ right to be forgotten à you have the right to request Alsense
Motorsport, without undue delay, to delete your personal data in the following
situations:
o
Your
personal data is no longer needed for the fulfillment of the purposes for which
they have been collected or initially processed by Alsense Motorsport;
o
If you
withdraw your consent based on which the processing was made;
o
If you
object to the processing of personal data on the basis of legitimate interests
and there are no legal justified grounds or any overriding legitimate interests
of Alsense Motorsport to continue the processing activity;
o
If you
object to the processing of your personal data based on direct marketing
purposes, including profiling to the extent that it is connected to the
performance of direct marketing activities;
o
If your
personal data have been unlawfully processed;
o
If your
personal data must be deleted to comply with a legal obligation to which
Alsense Motorsport is legally bound.
Right to restrict the processing of your
personal dataà you have the right to request Alsense
Motorsport to restrict the processing activity in those cases when one of the
following applies:
o
The
accuracy of your personal data is contested by you for a period which allows Alsense
Motorsport to check the accuracy of the personal data;
o
The
processing is unlawful and you oppose your personal data deletion and you
request the restriction of their use instead;
o
Alsense
Motorsport no longer needs your personal data for the described processing
purposes, but the personal data are requested by you for the establishment,
exercise or defense of a legal claim;
o
You object
the processing based on legitimate interests, the processing being restricted
for the necessary time for checking whether the legitimate interest of Alsense
Motorsport override your legitimate interests.
Right to data portability à you have the right to receive from Alsene
Motorsport the personal data relating to you and which you provided, in a
structured format, commonly used and which can be automatically read and to
send such data to another data
controller when the technical means allows it to. You have this right only when
the processing is based on your consent or when the processing is carried out
by automated means of processing.
Right to object à you have the right to object, on grounds relating to your situation, to
the processing based on the legitimate interests of Alsense Motorsport. Alsense
Motorsport will no longer process your
personal data unless the Company demonstrates that it has compelling and
legitimate grounds which justify the processing and override your interests,
rights and freedoms or that the purpose is the establishment, exercise or
defense of a legal claim.
Automated
decision-making process, including profiling à you have the right not to be subject to a
decision based solely on automated processing, including profiling, which
produces legal effects upon you or which affects you in a similar manner to a
significant extent.
Right to lodge a
complaint with the competent authority responsible for protecting the personal
data, the National Supervisory Authority for Personal Data Processing.
TECHNICAL DATA
GENERATED BY THE USAGE OF THE VECHICLE OVER WHICH THE PRODUCTS ARE MOUNTED AND
CAPTURED BY THE TIRE TEMPRETURE SENSORS ARE NOT PROCESSED BY ALSENSE
MOTORSPORT. SUCH TECHNICAL DATA CAN ONLY BE CAPTURE IN YOUR OWN TERMINAL
EQIPMENT WHICH IS NOT ACCESSED OR CONTROLLED BY ALSENSE MOTORSPORT. IF YOU ARE
GOING TO PROVIDE SUCH DATA TO ALSENSE MOTORSPORT SUCH DATA WILL BE PROVIDED
UPON YOUR REQUEST FOR SUPPORT SERVICES AND ONLY BY YOU, ALSENSE MOTORSPORT
DOESN’T OWN THE POSSIBILITY TO REMOTELY ACCESS IT. CONSIDERING NO RELATION TO
OTHER DATA CATEGORIES, FOR ALSENSE MOTORSPORT SUCH TECHNICAL DATA IS ANONYMOUS
DATA AND GDPR IS NOT APPLICABLE.