Effective as of [2020-09-28].

I. Introduction

Welcome to the Faurecia Aptoide’s privacy notice.

Faurecia Aptoide respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website, regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

II. Important information and who we are

Faurecia Aptoide Automotive, S.A., a Portuguese company, with the identification number ID 515 741 540 and principal place of business at Rua Soeiro Pereira Gomes, Lote 1, 3.º Dto., 1600-198 Lisboa, Portugal, is the controller and responsible for your personal data (collectively referred to as “Faurecia Aptoide”, “we”, “us” or “our” in this privacy notice).

This privacy notice aims to give you information on how Faurecia Aptoide collects and processes your personal data through your use of this website.

Please also read Faurecia Aptoide’s Terms of Service (“Terms”), which describes the terms applicable to your use of our website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

III. Contact details

You have the right to make a complaint at any time to the Portuguese Data Protection Commission (CNPD), the Portuguese supervisory authority for data protection issues (www.cnpd.pt). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD so please contact us in the first instance.

IV. Third-party links

Our website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or app you use.

V. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will only use your personal data when the law allows us to. We will use the following categories of your personal data:

  • Identity Data: name, e-mail, birthdate, address, username, phone number, name of the company and website, if applicable.
  • Technical Data: includes internet protocol (IP) address, country, User Agent (browser type and operating system).
  • Profile Data: includes your username and password.
  • Payment Data: Customer unique identifier, package name of the app where the item was bought, item purchased, country of purchase, origin of the transaction, price, payment method, payment key, timestamps.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you the services or to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

VI. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
    1. create an account on our website;
    2. use our website;
    3. give us some feedback or contact us.
  • Interactions with automotive manufacturers. We may have access to your Identity Data when you register an account in the car manufacturer platform which gives you access to our platform.
  • Automated technologies or interactions. As you interact with our website, we may automatically receive, collect or generate Technical Data. We collect this personal data by server logs, plug-ins and other similar technologies.

VII. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to provide you the services or to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

VIII. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data based on more than one lawful ground, depending on the specific purpose for which we are using your data. Please Contact us if you have doubts about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Categories of data Lawful basis for processing
To register you as a new user.
  • Identity Data
Provision of services to you.

To process and deliver purchases including:

  • Manage payments, fees and charges;
  • Collect and recover money owed to us.
  • Identity Data
  • Technical Data
  • Payment Data
  • Performance of a contract with you.
  • Necessary for our legitimate interests (to manage our relationship with developers providing the products purchased).

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy.

  • Profile Data
  • Provision of services to you.
  • Necessary to comply with a legal obligation.
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • Identity Data
  • Profile Data
  • Technical Data
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
  • Necessary to comply with a legal obligation.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

IX. COOKIES

We use cookies in this website. Cookies are small text files that identify your computer in our server. Cookies do not, of themselves, identify individual users, but only the computer used. Cookies are not used for the collection of personal data.

In our website we only use functional cookies, which allow our website to remember choices you make, (such as your username, language or the region you are in) and provide enhanced, more personal features).

The table below describes the cookies used by our website:

Name Description Expiration
CAR-USER-PROD
  • To keep you logged on in your user account
24 hours, unless you choose the “Remember me” function when you login, case in which it will expire after 30 days

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.wikipedia.orgwww.allaboutcookies.orgwww.aboutcookies.org.

X. Disclosures of your personal data

We may share your personal data with data processors to allow us to provide you with our services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The categories of third parties having access to your personal data are the following:

  • Service providers. acting as processors, to provide us with the following services:
    • Hosting services provided by Amazon Web Services EMEA SARL.
    • use our website;
    • Payment processing provided by Adyen N.V..
  • Regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

XI. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

XII. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. We may also anonymise your personal data (so that it can no longer be associated with you) for statistical purposes in which case we may use this information indefinitely without further notice to you.

Considering the above, we have implemented the following retention periods:

Type of Data Retention Period
User Data Deleted if there is no activity for 5 years
Payment Data 10 years

XIII. Your legal rights

Under data protection laws in relation to your personal data you are entitled to exercise the following rights:

  1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

 

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.