PRIVACY POLICY OF SEAT Plus FROM SEAT, S.A.

 

The present Privacy Policy aims at explaining when and why we collect your personal data, and how we use them, by using the SEAT Plus application (hereinafter, the “Application”).

Who is the data controller of your personal data?

Data controller identity: SEAT, S.A., with Tax Identification Number A-28049161

Address: Autovía A-2, Km. 585, Martorell (Barcelona)

Mail: customercare@seat.es

Data Protection Officer contact details: dataprotection@seat.es

What is the purpose and the lawful basis for the processing of your data?

SEAT, S.A. (hereinafter, “SEAT”) will process the personal data you provide us, as well as any other personal data that SEAT may have access as a consequence of your navigation, for the following main purposes:

1.      Managing your registration in the Application, allowing you to use the functionalities included in the Application;

2.      Attending your questions and doubts regarding the Application functionalities;

3.      Managing the relationship and communication between you and your favorite selected SEAT Official Car Dealer and After-Sales service.

4.      Geo-locating and providing your device location (for example: in event of an accident or mechanical breakdown); You can deactivate the geolocation from the device settings, taking into account the usage limits of the Application that this could imply.

5.      Assisting you during your trips by geo-locating both your position and your vehicle, only in case you previously connected a special connectivity device (hereinafter, “SEAT Plus DataPlug”) and correctly completed the relevant matching process with your vehicle.

6.      Collecting and analyzing statistic parameters from your vehicle, only in case you previously connected SEAT Plus DataPlug and correctly completed the relevant matching process with the Application.

7.      Managing your vehicle alerts and proposing an appointment with your favorite SEAT Official Car Dealer and After-Sales service, only in case you previously connected the SEAT Plus DataPlug and correctly completed the relevant matching process with your Application.

8.      “Expenses Display”: with this functionality, only in case (i) you previously connected SEAT Plus DataPlug and correctly completed the relevant matching process with the Application and (ii) have authorized sending push notifications in Application, when refueling  your vehicle (and therefore, the value of the metric "fuel level" has increased), you will receive a notification inviting you to add the expense in the “Expenses Display” section of the Application.

For purposes described above, push notifications may be sent to your device with advice and informative notices related to the Application. You can deactivate notifications from the device settings, taking into account the usage limits of the Application that this could imply.

 

The legal basis for the processing of your personal data is the provision of the service for the execution of the Contract, as detailed in the Terms of Use.

The processing of your personal data for the purposes abovementioned is necessary for the provision of the service.

On the other hand, and only if you have consented it, SEAT will process your personal data for the following additional purposes:

- Marketing activities (“Communication that matters”): SEAT will send you information and special promotions about products or services of SEAT to provide you the best experience with your car. You can receive it through print, electronic and telephone means.

- You can revoke your consent at any time by sending an e-mail to customercare@seat.es or manage it by yourself through SEAT ID Portal: seatid.vwgroup.io/account.

- Profiling activities (“Get more with sense”): SEAT will send you information about products and services provided by SEAT fitted to your profile. For this kind of activities, it will be necessary to combine your data with internal and, occasionally, external sources.

You can revoke your consent at any time by sending an e-mail to customercare@seat.es or manage it by yourself through SEAT ID Portal: seatid.vwgroup.io/account.

- Disclosure to your SEAT Importer for marketing purposes (“Together we are better”): SEAT will disclose your personal data to your Importer in order to send you offers and special promotions fitted to your profile regarding services and products that may be of your interest. Through the disclosure, the SEAT Importer will become the data controller of your data so, in relation to this purpose, you can exercise your rights conferred by GDPR and data protection local laws following the instructions giving by them. 

In case, you have given your consent to the disclosure of your data to the Importer for marketing activities and you want to withdraw it, you should turn to the Importer as data controller of these communications.

The lawful basis for processing your personal data for these purposes is your consent.

What categories of data do we process?

In the context of functionalities offered by the Application, and subject to the purposes you previously consented, SEAT will process the following data categories:

-        Identification and contact details data;

-        Data regarding your vehicle identification;

-        Data regarding status and metrics about your vehicle;

-        Data regarding location information and geolocation.

The personal data processed in the Application may come from external sources in case you previously connected SEAT Plus DataPlug with your vehicle.

What other recipients will the data be disclosed to?

SEAT will disclose your personal data to third parties when such disclosure is laid down by law.

SEAT will disclose identification and contact details data to the SEAT Official Car Dealer and After-Sales service of your choice, together with information about your vehicle status, to arrange and manage appointments. These kinds of alerts can be:

·        Red or immobilized car alerts where SEAT, through the roadside assistance service included with your car warranty will assist you offering the towing service to get to the nearest SEAT Service Partner.

·        Alert changed: Less important alerts such as a problem with your tires or lights or any relevant warning light that appears in the vehicle may be disclosed to your SEAT Service Partner that will be allowed to get in touch with you and, if you are interested, schedule an appointment in order to solve the vehicle’s problem.  

Additionally, inform you that SEAT has signed agreements with third parties who act as data processors and have access to data for the provision of services. SEAT, mainly contracts the virtual infrastructure as "cloud computing" model with Salesforce.com, Inc., an entity based in the United States of America, with necessary authorization from the Director of the Spanish Data Protection Authority to carry out international transfer of personal data. Likewise, Volkswagen AG provide us the service for managing the relation between the requests of the customer and the SEAT Service Partner for the car alerts and appointments, and to comply with this purpose, they also have contracted Salesforce, Inc. having the consideration of a subprocessor. This being an international transfer of personal data is carried out under EU Standard Contractual Clauses. 

Moreover, some of the functionalities of the App are offered through third parties, such as Google in the case of using the map functionality. In that case, these third parties may process the personal data as data controllers, being subject to the respective privacy policies that can be accessed through the application that corresponds in each case.

How long do we retain your personal data?

We will retain your personal data as long as necessary to provide you with the functionalities included in the Application, and, in any event, until you ask for their elimination. In any case, we will retain your data to comply with any legal requirements corresponding to each category of data.

What are your rights as affected individual?

You can exercise the following rights before SEAT in your condition of data subject:

-        Access: You can get information if SEAT processes your personal data, as well as consult your personal data included in the SEAT files.

-        Rectification: You can modify your personal data when it´s inaccurate as well as complete those that are incomplete.

-        Erasure: You may request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes that were collected.

-        Objection: You may request that your personal information not be processed. SEAT will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.

-        Limitation of the processing: You can request the limitation to the processing of your personal data in the following cases:

·        While objection of the exactitude of your personal data is being checked;

·        When the data processing is illegal, you object the deletion of your data and request the limitation of its use;

·        When SEAT does not need to process your data, but you need it for the exercise of defense claims;

·        When you have opposed the processing of your personal data for the fulfillment of a mission of public interest or for the satisfaction of a legitimate interest, while it is verified if the legitimate reasons for the processing prevail over yours.

-        Portability: You can receive, in electronic format, the personal data that you have given us and those that have been obtained from your contractual relationship with SEAT, as well as to transmit them to another entity.

You can exercise these rights by sending (i) a written request to SEAT, S.A, Customer Service department, Autovía A-2, Km. 585,  (08760) Martorell, Barcelona (Spain) or (ii) by sending an email message to the email address “customercare@seat.es”. The exercise of these rights is free of charge unless of manifestly unfounded or excessive requests.

If you consider that SEAT has not processed your personal data in accordance with the applicable regulations, you can file a complaint with the competent control authority through the website www.agpd.es.