Privacy policy
Through this privacy statement, SOREMAR (hereinafter: «OMODA & JAECOO » or «we/our») wishes to inform the individuals whose personal data it collects, uses and stores (that is, processes) through its general website omoda-jaecoo-sxm.com. These individuals may include business contacts, suppliers, directors, agents, prospects/customers and their representatives, employees and/or shareholders, where applicable. OMODA & JAECOO is considered a data controller for such processing activities. In this statement, we use the word « you » to refer to any individual covered by this statement.
Other services offered by OMODA & JAECOO may be covered by a separate privacy statement.
1. The personal data we collect
Personal data is information relating to an identified or identifiable natural person. We use personal data to run our business, provide our services, enter into a contract and protect our interests. With regard to the general and special websites, we process personal data if you provide it to us, or when we collect it from you, for example in the context of your dealings with us or in the context of your use of the general or special website.
Depending on the processing activity, the information we process about you may consist of:
First name and surname;
Company name;
Telephone number;
Email address;
Address, City and Country;
Data relating to your equipment, such as an IP address (this information is not always considered personal data);
Data relating to your preferred model, accessories and test drive
Data relating to your use of the general or special website.
In order for us to provide our services to you, providing certain personal data is mandatory. If you do not provide the personal data indicated as mandatory on the general or special website, we may not be able to provide our services to you.
2. How personal data is accessed
Access to your personal data is restricted. Within our organisation, individuals are only authorised to access personal data on a need-to-know basis. In certain cases, we share your personal data with third parties. OMODA & JAECOO may share your personal data with:
Internal departments involved in processing a transaction to which you are – directly or indirectly – a party, such as finance, sales, marketing and operations;
Customers, suppliers or service providers of OMODA & JAECOO, acting as data processor or data controller, such as hosting providers, IT service providers and external advisers, accountants and lawyers;
supervisory authorities and other government bodies, in order to comply with legal obligations;
Third parties involved in a transaction (such as a merger or acquisition) under which (part of) our business is sold or transferred.
National importers, in order to respond to a request for information or arrange a test drive
Local dealers, in order to respond to a request for information, make an offer on request or schedule a test drive.
We will only transfer your personal data to the third parties mentioned above for the purposes set out in the privacy statement, and only to the extent permitted under applicable law and regulations.
The third parties to whom we transfer your personal data are themselves responsible for complying with applicable data protection law, unless they act as our data processor. We are not liable or responsible for how these third parties handle your personal data or comply with applicable data protection law, provided they act as an independent data controller.
3. International transfers of personal data
At present, we do not transfer personal data to recipients located outside the EEA. However, should we transfer your personal data outside the EEA in the future, we will inform you in advance. We will then put appropriate safeguards in place to ensure adequate protection.
4. Our legal bases for processing
Under data protection law, we are only permitted to process personal data if we can rely on one or more of the legal grounds for processing. These are:
Consent – Your consent, where legally required.
Contract – Processing is necessary for the performance of a contract with you/your company or to take steps at your request before entering into a contract.
Legal obligation – Processing is necessary in order to comply with our legal obligations.
Public interest – Processing is necessary for the performance of a task carried out in the public interest.
Legitimate interests – Processing is necessary for our legitimate interests or those of a third party. We, or a third party, have legitimate interests in conducting, managing and administering our respective businesses efficiently and properly, and in processing your data as part of those interests. Those interests also include, among others, IT security, transaction tracking such as offers, test drives and marketing. Your data will not be processed on this basis if our interests or those of a third party are overridden by your own interests, rights and freedoms.
Vital interests – Where processing is necessary to protect your vital interests (or those of someone else) and you are unable to give your consent. This is only likely to apply in very exceptional circumstances, such as a medical emergency.
5. Purposes and legal basis for processing personal data
OMODA & JAECOO processes personal data for the purposes described below. As explained above, processing in this context may include transfers to third parties and/or outside the EEA. From time to time, we may publish specific notices setting out (additional) details concerning particular processes or programmes adopted by us.
Purpose Legal basis
Preparing and/or establishing and maintaining a customer or supplier relationship with you or the organisation you represent. Contract Legitimate interests
Responding to your requests for information or enquiries. Contract
Legitimate interests
Ensuring physical, system and IT security, including the security of our website. Contract
Legitimate interests
Analysing the use of our website, including clicks and other data relating to its use of the website, primarily through Google Analytics. Legitimate interests
Corporate transactions/due diligence. In the context of a possible merger or takeover, your personal data may be provided to a potential buyer or investor. Legitimate interests Dispute resolution, defence of legal claims, compliance. Legal obligation
Legitimate interests Public interest
Keeping you up to date on new models if you so wish, by providing us with your email address, your name and your country of residence. Consent (where applicable) Legitimate interests.
Providing you or your company with brochures, marketing information or advertising, by email, post or telephone. To the extent required by applicable law, your prior consent will be obtained. Consent (where applicable) Legitimate interests.
We are not engaged in any automated decision-making without human intervention that affects data subjects.
6. Your rights
We are required to inform you of your rights:
Right of access, meaning that you can make a request to obtain information about the personal data we process about you;
The right to rectification or correction of your personal data;
The right to erasure of the personal data concerning you;
The right to restriction of processing;
The right to data portability, meaning that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
The right to object to certain types of processing;
The right to lodge a complaint about our processing of personal data with the competent supervisory authority – if you are not satisfied with our handling of your request or complaint;
The right to withdraw your consent, to the extent it was given.
Your rights, with the exception of (vii), may be exercised by submitting a request to us using the contact details included in this privacy statement, and only to the extent that you benefit from those rights under applicable law.
7. Retention period
We will not keep your personal data longer than necessary in light of the purposes set out in this privacy statement, unless law or regulation requires us to do so. Please note that we may be legally required to retain the personal data we hold about you (directly or indirectly) for a set period after the information has lost its relevance, for tax law and company law purposes.
8. Changes to this privacy statement
We may amend or update this privacy statement from time to time, to ensure the information is up to date. You will be informed of any change, if we are required to do so.
9. Contact
If you have any questions or comments about this privacy statement and/or the processing of your personal data, please contact: DPO@loret.fr
