1Identification of the data controller
AUTOCAFLER, S.L. (hereinafter, "the Controller" or "CAFLER") is the data controller responsible for the processing of the personal data obtained from users through the use of the website www.cafler.com, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "RGPD"); Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (hereinafter "LOPDGDD"); and Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (hereinafter, "LSSICE").
The Controller informs you that it has implemented the necessary security measures, of a technical and organisational nature, to guarantee and protect the confidentiality, integrity and availability of the data you provide to us.
To ensure the proper management of the processing of your personal data, for any matter you may require, you can contact the Controller through the following email address: soporte@cafler.com.
2For what purpose and on what legal basis do we process personal data?
| Purpose of the processing | Additional information | Legal basis |
|---|---|---|
| Management and provision of the services offered to customers through the CAFLER website or application. | Provision of the services contracted by the customer through the CAFLER website, which may include any administrative management necessary for the correct delivery of the service and/or the delivery of the product. | Relación contractualThe management, development and maintenance of the contractual relationship held with the customer. |
| To manage your registration as a user of the Application. | Should you decide to register as a user on our Application, we need to process your data to identify you as a user and give you access to its various functionalities, products and services that are available to you as a registered user. You can cancel your account by contacting Customer Service or in the "Unsubscribe" section of the Application. The data we collect about your activity, including your purchases, will remain linked to your account so that all the information can be accessed at once. You have the option to log in through a partner with whom you hold an account or by registering a new one. In that case, your credentials, as well as your name and email/telephone number, will be imported from your social network or partner account. If the third party sends us additional information from your public profile, unless you give us your authorisation, we will not retain this additional data. | Relación contractualThe management, development and maintenance of the contractual relationship held with the customer. |
| Compliance with the legal obligations that may arise from the relationship with the customer. | Compliance with any legal obligation that may arise from the contractual relationship held with the customer. | Obligación legalCompliance with CAFLER's legal obligations. |
| Sending commercial communications. | Sending the newsletter about CAFLER's new products or services. | ConsentimientoExpress consent of the customer expressed by ticking the box provided for this purpose. |
| Sending commercial communications about products or services similar to those contracted. | Keeping CAFLER's customers informed about products or services similar to those already contracted. | Interés legítimoCAFLER's legitimate interest in keeping its customers informed about its current offer of products or services. |
| Management and handling of the enquiries and requests for information sent through the website or Application. | To resolve any question that users may have about our products and/or services, providing the corresponding information. | Interés legítimoCAFLER's legitimate interest in providing a customer service suited to the needs of its customers and potential customers (in the context of receiving requests through social networks, forms, etc.), as well as the maintenance of the contractual and pre-contractual relationship. |
| To notify you of important changes or developments to the Privacy Policy or the Terms of Use. | To keep you informed about any relevant change to the Privacy Policy or the Terms of Use of the CAFLER website or Application. | Interés legítimoCAFLER's legitimate interest in providing you with up-to-date information about the conditions of the processing of your personal data and/or the terms of the service. |
| To keep evidence of the condition of the vehicle at the time it is handed over by the customer. | CAFLER may take photographs of the interior and exterior of your vehicle in order to keep due evidence of its condition (e.g. dents, damage, objects stored inside, state of cleanliness) at the time it is handed over by you. | Interés legítimoCAFLER's legitimate interest in holding due evidence of the condition of the vehicle at the time it is handed over by the customer, in order to prevent fraudulent conduct or to be able to demonstrate the correct custody of the vehicle during the provision of its services. |
| Anonymisation of the personal data provided and of the photographs taken of the vehicle. | CAFLER may anonymise the photographs taken in the context of capturing evidence of the condition of the vehicle, for the purpose of producing anonymised statistical analyses on the typology of its customers (for example, what percentage live in large cities, have a pet or do winter sports). Such information, as well as the statistical analyses produced, which under no circumstances will identify its customers directly or indirectly, will allow the commercial strategy to be focused more efficiently and provide value to its commercial partners. | Interés legítimoCAFLER's legitimate interest in knowing the average profile of its users and being able to orient the website and the services offered accordingly. |
| To carry out personalised commercial communications following the profiling of its customers. | CAFLER may analyse the photographs taken of the exterior and interior of your vehicle (such as, for example, the vehicle model and its condition, the mileage covered or the vehicle's equipment, such as baby seats, pet accessories or sports equipment) for the purpose of building commercial profiles in order to send personalised commercial communications by electronic means, both of its own products or services and of third parties. To this end, CAFLER will apply analytical models that allow it to better understand the tastes or preferences of its customers, as well as their financial capacity, processing the information indicated and that generated internally as a result of the provision of its services. | ConsentimientoExpress consent of the customer expressed by ticking the box provided for this purpose. |
| Communication of data to its commercial partners for the purpose of sending personalised commercial communications. | CAFLER may communicate your personal data to its commercial partners so that they can offer you their products and services through various channels, including electronic means. Such partners may belong to the insurance, banking, automotive, energy or retail sectors, depending on the specific consent you have given us in each case. | ConsentimientoExpress consent of the customer expressed by ticking the box provided for this purpose. |
| Use of Cafler Chatbot. | Through this functionality the Controller implements an informative chatbot with personalised behaviour to respond to user enquiries and send them alerts, notifications and reminders under specific conditions about the services offered. | ConsentimientoThe express consent of the user by ticking the corresponding box at the time of collecting their data. |
| Publication of testimonials. | In the event that the user wishes to publish their opinion on the website. | ConsentimientoThe express consent of the user by ticking the corresponding box at the time of collecting their data. |
| Installation of cookies. | We use cookies to differentiate between our users, learn more about their preferences and offer them a more personalised browsing experience. For more information, see section 7 of this Privacy Policy. | ConsentimientoThe express consent of the user by ticking the corresponding box at the time of collecting their data. |
| Satisfaction surveys. | To use your data to contact you, both by electronic and non-electronic means, to obtain your opinion on the service provided. | Interés legítimoThe legitimate interest of the Controller in consulting its users on their degree of satisfaction in relation to the goods and services acquired. |
| Anonymisation of data for statistical purposes. | To carry out a process of anonymisation of your personal data for the purpose of producing reports and statistical studies using aggregated data, which allow us to analyse trends and optimise our services. | Interés legítimoThe legitimate interest of the Controller in anonymising the personal data collected to fulfil its own purposes without resorting to the use of personal data. |
In relation to the purposes indicated above that are based on the legitimate interest of the Controller, the user may request additional information about how we have assessed our legitimate interest and their own rights and interests by contacting us at soporte@cafler.com.
Failure to provide the personal data necessary to carry out those purposes covered by the taking of pre-contractual measures or the maintenance of the contractual relationship will mean, for the user, the impossibility of subscribing, registering or receiving the services provided by the Controller, since the processing of such data is necessary for the provision of the services offered.
3To which recipients will your data be communicated?
The Controller may communicate your personal data to Public Bodies and Administrations, only when necessary to comply with the applicable legal obligations. It may also communicate your data to subsidiaries for internal administrative purposes.
Additionally, and only if you give us your consent to do so, we may communicate your personal data as detailed in the section "For what purpose and on what legal basis do we process your personal data?", to companies in the insurance, banking, automotive, energy or retail sectors so that they can offer you their products or services, depending on the specific consent you have given us in each case.
In addition, the Controller works with certain external service providers that process your personal data on its behalf, such as:
- Service providers to deliver, run and support our IT infrastructure.
- Self-employed or freelance drivers who collaborate with the Controller in providing the services offered.
- Cafler Chatbot provider.
The Controller follows strict criteria for selecting service providers in order to comply with its data protection obligations, and formalises with them the corresponding Data Processing Agreement, in accordance with Article 28 of the RGPD. Under no circumstances do these providers subcontract services that involve any processing of personal data with third parties without the prior authorisation of the Controller.
4Are there international data transfers?
The Controller does not carry out international data transfers to third countries within the framework of the data processing activities set out in this policy.
5For how long will we keep your personal data?
The retention period for your personal data will be determined according to the duration of your relationship with CAFLER and the periods established by law. In this regard, the criteria that CAFLER uses to set the retention periods for your personal data have been determined in accordance with the requirements established in the applicable legislation, regulations and regulatory guidelines, as well as CAFLER's operational requirements related to the correct management of the existing relationship with the different categories of data subjects.
In this regard, your personal data will be kept as long as you do not revoke the consent given or you maintain any commercial or contractual relationship with CAFLER.
Once this relationship has ended, your personal data will be deleted at the moment when all the necessary actions have been carried out to manage and conclude any obligation that may remain pending between the parties, carrying out during that period all the necessary administrative tasks, except in those cases in which the processing of personal data is covered by legitimate interest or the consent given, the data of which will be processed until the user objects to the processing (unless compelling legitimate interests on the part of the Controller prevail) or withdraws their consent.
Notwithstanding the above, your personal data will be kept duly blocked, as long as liabilities may arise from the performance of our contractual or pre-contractual relationship, as well as for compliance with other legal obligations on the part of CAFLER.
In this respect, CAFLER guarantees that it will not process the personal data unless it is necessary for the formulation, exercise or defence of claims or when it is required to provide them to the Public Administration, Judges and Courts during the limitation period of its rights or legal obligations. Subsequently, your personal data will be deleted.
6What are your data protection rights?
The user may contact the Controller whenever they deem appropriate, and may exercise their rights:
- Right of access: you can request access to and copies of your personal data.
- Right to rectification: you can request that your data be amended if you believe it is inaccurate, and request that further information be added if you believe it is incomplete.
- Right to erasure: you can request that your personal data be deleted if it is no longer necessary for the purposes identified above; if it has been processed unlawfully or for compliance with the applicable legislation.
- Right to restriction: you can request that we restrict the processing if you contest the accuracy of your personal data; if it is unlawful and you object to its erasure; if you need it for the establishment, exercise or defence of legal claims; or if you have exercised your right to object.
- Right to object: the user can object to the processing of their personal data so that we stop processing it.
As well as the right to the portability of your data and not to be subject to automated decisions, and to withdraw your consent at any time, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal, by means of a request addressed to AUTOCAFLER, S.L., with registered office at Carrer de Balcells, 29, Planta baixa, Gràcia, 08024 Barcelona, or to the email address soporte@cafler.com.
Where there are reasonable doubts in relation to the identity of the natural person making the request, the provision of the additional information necessary to confirm the identity of the data subject may be requested.
Finally, in the event that the user wishes to have more information about their data protection rights or needs to file a complaint, they may contact the Spanish Data Protection Agency, with offices at Calle Jorge Juan, 6, 28001 Madrid, in order to safeguard their rights (www.aepd.es).
8Modification of the privacy and data protection policy
AUTOCAFLER, S.L. reserves the right to modify this privacy and data protection policy in order to adapt it to the regulations in force at any given time and to the instructions or recommendations issued by the supervisory authorities, which is why we recommend reading it before each access to and browsing of the website.
9Keeping your personal data up to date
We strive to maintain the accuracy and integrity of the personal data we hold. It is essential that you inform us of any update to your contact details or other personal data to ensure that we have the most up-to-date information about you. Please contact us to make any update through the email address: soporte@cafler.com.
For any question relating to the processing of your personal data, you can write to us at soporte@cafler.com.