Privacy statement Bentley Leusden (part of Pon Luxury Cars B.V.)
The Pon Luxury Cars B.V. considers the protection of personal data essential. We therefore process your data with the greatest possible care.
With this privacy statement we inform you about how we handle personal data.1. Who is responsible for processing your data?
In this privacy statement the Pon Luxury Cars describes B.V. (hereinafter: "Pon Luxury Cars" or "we") how it handles your personal data as a controller. We are affiliated with Pon Holdings B.V. ("Pon") and are part of the Pon group.2. What is personal data?
Information about an identified or identifiable natural person is personal data. Whether certain information should be qualified as personal data also depends on whether Pon Luxury Cars has legal means that it can reasonably be assumed to use to identify a data subject. For example, we also consider your license plate and chassis number as personal data.3. Personal data that we process
We process personal data about you because you provide us with data when entering into an agreement with us, but also when you use our services and thereby provide us with data, or allow us to record data about your interests and preferences.
Information provided to us
If you enter into an agreement with Pon Luxury Cars, we need the following personal information from you:
- name and address;
- contact details (telephone numbers, e-mail addresses);
- date of birth;
- customer number (s);
- financial data (bank account information, quotes, invoices).
In addition, as part of the implementation, Pon Luxury Cars processes an agreement with you or provides a service to you with the following data that may qualify as personal data:
- chassis number and model of your vehicle;
- technical data about your vehicle;
- license plate of your vehicle;
- maintenance history of your vehicle;
- ownership history of your vehicle (registration data);
- other data relevant to the relevant agreement.
Information about your use of our services and / or products
If you use services from Pon Luxury Cars or otherwise have contact with us, we process the following data in the context of our service provision - depending on the precise use you make of it - that may be regarded as personal data:
- data that relates to your peripheral equipment, such as a MAC address, IP address or other number;
- your communication preferences and settings;
- data that we link to certain patterns, such as a status in the profile that we compile about you based on your consumption behaviour (for example: the frequency with which you make a purchase or purchase a service);
- surfing behaviour, determined on the basis of our own observations or cookies (see also article 9 of this privacy statement);
- customer satisfaction data;
- information about your use of Customer Care.
We do not intend to collect data from website visitors under the age of 16. We advise parents to be involved in the online activities of their children in order to prevent Pon Luxury Cars from processing their personal data.5. Processing: foundations and legitimate interests
The processing of personal data takes place on the basis of the following principles from Article 6 of the General Data Protection Regulation:
- Execution of an agreement with you
- Legal obligation
- Fulfilment of a task in the public interest
- The legitimate interest of Pon Luxury Cars or a third party
Legitimate interests include: marketing, advertising, security, (crime) prevention, IT management, research and analysis of own products or services, business management, legal affairs, internal management.6. Purposes for processing personal data
Pon Luxury Cars processes your personal data for the purposes stated below. The figure behind each goal corresponds to the basis stated in Article 5 of this privacy statement.
- Building and maintaining a customer relationship, including maintaining a direct relationship between the responsible and related financial service providers, including for commercial purposes [basis: 2, 5]. Processing orders (including invoicing), processing in financial administration and logistical processing [basis: 2, 5].
- Providing customer service including services related to the purchase of services and products, fulfilling warranty obligations and product revocations for our own services, handling complaints and requests [basis: 2, 3, 4 or 5].
- Maintaining communication in certain cases to contact users proactively in the context of vehicle faults or malfunctions or to plan service appointments including enabling mobility services [basis: 2 or 5].
- Conducting market research to improve our business operations, brands, services and products [basis: 5].
- Communicating with stakeholders and offering a loyalty program [basis: 1 of 5].
- Approach you with offers or other commercial information. You always have the option to unsubscribe by objecting. For all communications it is indicated how you can do this [basis: 1 or 5].
- Improve the content of our communication by tailoring it to your personal preference [basis: 5].
- The (further) development and improvement of new and existing products and services [basis: 5].
- Measuring customer satisfaction, providing management information and determining the overall business strategy [basis: 1 of 5].
- Organizing events for data analysis purposes to improve or develop products or services, where participants of these events work with personal data in (pseudo) anonymous form - not directly traceable to you as a natural person - to the extent permitted by applicable law [basis: 5].
- Providing services on the internet and via app functionalities, including the provision of relevant commercial messages in these apps [basis: 1, 2 or 5].
- Complying with legal obligations, settlement of disputes and enforcement of our rights and agreements [basis: 3, 4 or 5].
- Improving data quality using address validation techniques [basis: 5].
- Linking and analysing cookies from our websites to known customer data. We do this to match the content of our communication as well as possible to your personal preference [basis: 1 of 5].
- Being able to offer a test drive or otherwise temporarily making a vehicle available. Hereby we can ask you to identify you with a valid proof of identity and / or when necessary we make a protected copy of your driver's license or identity card / passport for the duration of the use of the vehicle. We do this to establish your identity and to make it possible to make a declaration if there is a suspicion of theft or there is evidence of demonstrable damage or misconduct. [basis: 2].
Pon Luxury Cars shares your personal data with third parties in the following cases, among other reasons. The figure behind each goal corresponds to the basis stated in Article 5 of this privacy statement:
- with affiliated financial service providers with the aim of offering connecting financial services [basis: 2];
- with authorized dealers or service partners from the Pon distribution network [basis: 1, 2 or 5];
- if we are legally obliged or authorized to provide personal data to third parties [basis: 3];
- if we suspect a violation of the rights of third parties, of criminal offenses or of abuse, we may provide personal data to third parties who have a legitimate interest in doing so or to bodies that serve the public interest. These can also be enforcement authorities, such as the Public Prosecution Service or supervisors [basis: 3, 4 or 5];
- Pon Luxury Cars can also share your data with other business units within the Pon group for the implementation of an agreement with you, or for legitimate business interests, such as conducting a central administration or customer service, and analysing our services to you [basis : 5].
- with parties who assist Pon Luxury Cars in its services and are not a processor (such as accountants and (legal) advisers) [basis: 5];
- for business economic purposes (such as the sale of business activities or shares or a reorganization) [basis: 5].
Pon Luxury Cars also uses third-party services that act as 'processors' (for example, hosting service providers, mobility service providers and research agencies, for the purpose of conducting market research or customer satisfaction surveys. These service providers will only process personal data in accordance with the instructions and under the control from Pon Luxury Cars.
If personal data is sent to a recipient abroad, this usually only happens to a recipient in a country that, according to the European Commission, offers a level of protection that is suitable for personal data. If personal data is sent to a recipient in a country that does not offer an adequate level of protection, it will
Pon Luxury Cars ensure that the legally required guarantees are taken. If you wish to receive further information about the transfer of your personal data to countries outside the European Economic Area, you can contact the Data Protection Officer of Pon (see article 12).8. How long we keep data
We store personal data in accordance with our internal data retention policy and / or as long as (i) you are a Pon Luxury Cars customer or continue to show interest in the services of Pon Luxury Cars, (ii) we are legally obliged to store data, or (iii) we believe on good grounds that we may retain data, as necessary.9. Mapping website visits
You have the right to know which personal data we have recorded about you and to whom we have provided your personal data. For this you can contact us via customer service. Pon Luxury Cars will make every effort to respond within the legal period. We can disregard excessive requests. In addition to the right to view, you also have the following rights with regard to our processing of your personal data:
- the right to withdraw your consent, to the extent that our processing of your personal data is based on it;
- the right to submit a complaint to the Dutch Data Protection Authority;
- the right to rectify / correct your personal data;
- the right to delete your personal data;
- the right to limit your processing concerning you;
- the right to data portability;
- the absolute right to object to direct marketing;
- the right to object to processing that takes place because of the justified interests of Pon Luxury Cars or a third party (depending on your personal circumstances).
You can only exercise your rights to the extent that the law grants you these rights. To ensure that the request for inspection has been made by yourself, we request that you send a copy of your proof of identity with this request. Hereby we also ask you to make the passport photo, MRZ (machine readable zone; the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) unrecognizable on this copy.11. Security and protection of data
Pon Luxury Cars applies appropriate security measures to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized changes as much as possible. Pon Luxury Cars has taken both technical and organizational measures to protect your personal data. These security measures are periodically reviewed based on threats.12. Contact
For questions and / or comments regarding this privacy statement you can contact:
Pon Luxury Cars B.V.
Pon Luxury Cars B.V.
Our Data Protection Officer can be reached by e-mail at firstname.lastname@example.org and by post via:
Pon’s Automobielhandel B.V.
T.a.v: 'Privacy Officer'
3800 VB Amersfoort
The way in which we process personal data, and the composition or amount of data we process may change. That is why we reserve the right to adjust this privacy statement. You will be notified of a change if necessary. This Privacy Statement will always state the last date of the change. Earlier versions can be consulted below: