MOLLER CLUB PRIVACY POLICY
In this Privacy Policy we explain how we process personal data when we provide you with access to Moller Club, as well as when you communicate with us. This Privacy Policy describes policies and practices regarding our collection and use of Your personal data, as well as sets forth Your privacy rights. We recognise that personal data protection is an ongoing responsibility, and we may from time to time update this Privacy Policy, as we undertake new personal data processing practices.
Please take your time to carefully read this Privacy Policy and, if you have any questions, please feel free to contact us.
1. DEFINITIONS
The following terms are defined as follows in this Privacy Policy:
- We / Controller / Moller Auto - Moller Auto Baltic SIA, registration number 40203251094, legal address S.Eizenšteina iela 10, Rīga, LV-1079, Latvia.
- You / Moller Club member - an individual who is at least 18 years old, has applied for the Moller Club programme and whose membership in the Moller Club programme has been approved by Moller Auto.
- Moller Club programme – a loyalty programme created and maintained by Moller Auto.
- Moller Club app - a mobile application created and maintained by Moller Auto, designed for use on mobile devices. Moller Club members can join the Moller Club programme only using this application, see their missions and receive their Moller Club rewards.
- Moller Club account - an account created by the Moller Club member, where the Moller Club member’s missions and Moller Club rewards are stored.
- Partner - partner of the Moller Club programme that collaborates with Moller Auto. This collaboration may involve Moller Club missions and Moller Club rewards, or other forms of collaboration between the Partner and Moller Auto for the purpose of Moller Club programme. Each Partner retains the right to set individual policies for Moller Club missions and Moller Club rewards.
- Moller Club Missions - a task or set of activities designed to engage Moller Club members in experiences that enhance their automotive knowledge, encourage safe driving, or improve vehicle maintenance. Missions are interactive challenges that can be completed by following specific steps provided within the Moller Club app. Each mission offers a unique Moller Club reward upon successful completion.
- Moller Club rewards - a reward is a benefit or prize given to Moller Club members upon the successful completion of a mission.
2. ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?
We process your data specified in this Privacy Policy on these legal grounds:
- the data subject has given consent to their data processing (Article 6(1)(a);
- for performance of a contract to which the data subject is party (Article 6(1)(b) of the GDPR);
- for fulfilment of legal obligations and requirements of legal acts applicable to us (Article 6(1)(c) of the GDPR);
- for pursuing our legitimate interests and those of third parties (Article 6(1)(f) of the GDPR).
In the scope and under the conditions set by applicable legislation, one or several of the abovementioned legal grounds may apply to processing of the same of your personal data.
3. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE THEM?
3.1. Providing Moller Club Account via the Moller Club App, organising Moller Club Missions and issuing Moller Club rewards
In order for us to enable you to register the Moller Club Account via the Moller Club App, as well as participate in the Moller Club Missions and issue Moller Club rewards, we process Your personal data.
Providing Moller Club Account via the Moller Club App, organising Moller Club Missions and issuing Moller Club rewards
| Data categories |
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| Legal grounds for data processing |
Performance of a contract (Article 6(1)(b) of the GDPR).
Legal obligations and requirements of legal acts (Article 6(1)(c) of the GDPR) in the following areas:
Our legitimate interest to offer you the possibility to become Moller Club Members and enable you to participate in Moller Club Missions and win Moller Club rewards, based on your participation. |
Duration of data processing |
Chapter VI of the Privacy Policy lists cases and conditions where personal data of yours can be stored or otherwise processed for a longer period of time. |
3.2.Protection of our property and legal interests
We process your personal data in order to protect our property and interests and those of our Partners and other persons, collect evidence of, as well as to administer, manage and recover damages inflicted on us and our property.
Protection our property and legal interests
Data categories |
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| Legal grounds for data processing |
Our legitimate interest (Article 6(1)(f) of the GDPR):
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Throughout your use of the Moller Club App and 5 (five) years after the termination of the use of the Moller Club App. Chapter VI of the Privacy Policy lists cases and conditions when these personal data of yours can be stored or otherwise processed for a longer period of time. |
3.3. Moller Club App administration, support and Moller Club programme improvement
We process certain personal data when you use the Moller Club App, for the purpose of collecting statistical data and improving the quality of the Moller Club App, as well as Moller Club programme in general. We also use your data to personalize the Moller Club missions and rewards.
Moller Club App administration, support and Moller Club programme improvement
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Data categories
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| Legal grounds for data processing |
Our legitimate interest to analyse data in order to administer, improve the App, improve the Moller Club programme, personalize the Moller Club Missions and Moller Club rewards and create value both for you as a Moller Club member and for our business (Article 6(1)(f) of the GDPR). |
| Duration of data processing | Throughout your use of the Moller Club App. |
3.4.Providing customer service – inquiries, requests, complaints
If you contact us in writing (by e-mail or otherwise), we will store the fact of you contacting us and the information provided, including personal data, so that we can properly examine your request and/or respond to your question, request or complaint.
Providing customer service – inquiries, requests, complaints
| Data categories | E-mail address, other information pertaining to your inquiry, including, but not limited to, first name, surname, complaint, request, inquiry text, description of the circumstances of the complaint or another inquiry, documents supporting the complaint, request, inquiry, other information provided to us. |
| Legal grounds for data processing |
Legal obligation (Article 6(1)(c) of the GDPR). Our legitimate interest to provide customer service (Article 6(1)(f) of the GDPR). |
| Duration of data processing |
Complaints, claims, written requests related to the Moller Club programme and/or which may be related to disputes, shall be stored throughout the entire effective term of your use of the Moller Club App and no longer than for 5 years after you cease to use the Moller Club App, unless longer periods specified below apply. Chapter VII of the Privacy Policy lists cases and conditions when these personal data of yours can be stored or otherwise processed for a longer period of time. |
3.5.Direct marketing
If you agree to sign up for receival of Moller Club news and updates, we will process your personal data, providing you with offers and information on our or our Partners’ products and services that may be relevant for you.
Direct marketing
| Data categories | E-mail address. |
| Legal grounds for data processing | Consent (Article 6(1)(a) of the GDPR). |
| Duration of data processing | Until we receive your consent withdrawal in which case we will seize the data processing as soon as technically available. |
4. FROM WHAT SOURCES DO WE OBTAIN YOUR DATA?NO KĀDIEM AVOTIEM MĒS IEGŪSTAM JŪSU DATUS?
You
Generally, we receive some of your personal data directly from you.
From your use of the Moller Club App
We also collect data about you based on your actions, for example, we collect data about how you use our Moller Club App. This helps us to monitor the service we provide to you, to design improvements to Moller Club programme and to personalise Moller Club missions and Moller Club rewards.
5.DO WE SHARE YOUR DATA WITH OTHERS?
Service providers
In order to provide our services, we rely on various service providers (e.g. providers of server hosting, data centres, cloud computing, audit, accounting, legal, tax advisory services, administration of damages, and other services).
Our data processors we use are located in the Member States of the European Union or store data entrusted to them by us in the European Union.
Third parties
If necessary and legally justified, we also provide your data to separate data controllers, namely to the competent authorities, institutions, organisations, also other data controllers who are entitled to receive information in line with the applicable legislation and/or our legitimate interests, or based on your consent. Please see below a non-exhaustive list of examples of such situations:
- we have the right and the obligation to transfer information to the competent authorities (pre-trial investigation bodies, etc.) for the purposes of prevention of fraud, offence and crime prevention and investigation.
6. HOW LONG DO WE STORE YOUR PERSONAL DATA?
Personal data specified in this Privacy Policy shall be stored and otherwise processed for no longer than the period specified in Section 3 of this Privacy Policy for each relevant data category and for no longer than necessary to achieve the purposes for which the data were collected.
In those cases when the data storage period is not indicated in this Privacy Policy, your data will be stored no longer than necessary for achievement of the purposes, for which the data were collected, or for a period set by legal acts.
After the end of your data processing and storage period set in this Privacy Policy, we destroy your data or anonymise them irreversibly and reliably as soon as possible, within a period reasonably necessary for performance of such an action.
If different processing or storage periods can be applied to the same data category for different purposes in accordance with this Privacy Policy, the longest of the applicable periods shall apply.
Your personal data can be stored for a period longer than indicated in this Privacy Policy only when:
- your data is necessary for the proper administration of damages (for example, you have caused damage to us or other persons), examination and settlement of a dispute, complaint, the protection of our legitimate interests or those of third parties;
- that is necessary in order that we could defend ourselves from existing or threatening demands, claims or legal actions and exercise our rights;
- there are reasonable suspicions of violations, illegal activities, which are or may be a subject to investigation;
- this is necessary for ensuring the functioning, resilience, integrity of backup copies, information systems, traceability of operations, statistical and other similar purposes;
- there are other grounds provided for in legal acts.
7. YOUR RIGHTS
You, as a data subject, have certain rights under the GDPR, including the right:
- to request access to your personal data and get a copy thereof;
- to request rectification or restriction of inaccurate or incomplete personal data;
- to request deletion or restriction of personal data which are excessive or unlawfully processed;
- to object to the processing of your personal data;
- to request transfer of your personal data provided in a structured, machine-readable format;
- to withdraw your consent at any time if data processing is based on the data subject’s consent (withdrawal of the data subject’s consent shall not affect lawfulness of data processing before the withdrawal of the consent);
- to file a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcijas) (Elijas str. 17, LV-1050 Rīga, Latvia, e-mail: pasts@dvi.gov.lv), however, we would recommend contacting us first and we will try to resolve all your concerns together with you.
How can you contact us to exercise of your rights?
You can submit your request for the exercise of your rights to us in the following ways:
- submitting a request by e-mail at loyalty@mollerauto.lv , signed with qualified e-signature (e.g. by use of Smart-ID), or
- sending a request by e-mail at loyalty@mollerauto.lv, with a notarised copy of the personal ID document.
7.1. The right to access data processed and the right to obtain a copy of personal data
Should you wish to obtain a copy of your personal data, contact us at loyalty@mollerauto.lv .
7.2. Right to rectification of personal data
In case of changes in data presented by you to us in your Moller Club account (surname, e-mail address, telephone number, etc), or in case you think that the information processed by us about you is inaccurate or incorrect, you have the right to demand to modify, amend or correct such information.
7.3. Right to withdraw the consent
When we process your data on the basis of your consent, you have the right to withdraw your consent at any time and data processing based on your consent will stop.
You have the right to withdraw consent at any time by e-mail: loyalty@mollerauto.lv
7.4. Right to object to data processing, when processing is based on legitimate interests
You have the right to object to personal data processing, when personal data is processed based on our legitimate interests by e-mail: loyalty@mollerauto.lv ;
7.5. Right to erasure (right to be forgotten)
The right to erasure (“right to be forgotten”) of personal data being processed by Moller Auto that can be exercised from within the Moller Club app and by contacting us by email loyalty@mollerauto.lv except for the cases stipulated in Section 6;
7.6.Right to restriction of data processing
When there are certain circumstances indicated in personal data protection legislation (when personal data is processed unlawfully, when you challenge data accuracy, you stated an objection to data processing on the basis of our legitimate interest, etc.), you also have the right to restrict your data processing.
However, we must point out that, because of the restriction of data processing and during the period of such restriction, we may be unable to guarantee you all the Services.
In order to exercise this right, please contact us.
7.7. Right to data portability
In order to exercise this right, please contact us at loyalty@mollerauto.lv
7.8. Right to lodge a complaint
If you think that we process your data in breach of requirements of personal data protection legal acts, we always ask that you contact us directly at first. We believe that our good will efforts will be enough to disperse any doubts you may have, to answer your questions, to satisfy requests and correct any errors we made, if any.
If you are not satisfied with a solution we suggest or if, in your opinion, we are not taking actions that must be taken in order to satisfy your request, you will have the right to lodge a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcijas) (Elijas str. 17, LV-1050 Rīga, Latvia, e-mail: pasts@dvi.gov.lv ).
8. HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?
We use appropriate organisational and technical personal data security measures, including protection against unauthorized or unlawful processing of data and against accidental loss, destruction or damage. Such measures have been selected taking into account the risks that may arise for your rights and freedoms as those of a data subject.
We regularly monitor our systems for possible breaches or attacks, but it is not possible to guarantee full security of information transmitted online. With this in mind, you provide us with information by use of the internet connection at your sole discretion and assuming any associated risks.
9. YOU CAN CONTACT US AS FOLLOWS:
- Moller Auto Baltic SIA, registration number 40203251094, legal address S.Eizenšteina iela 10, Rīga, LV-1079, Latvia
- E-mail: loyalty@mollerauto.lv .