Privacy Policy.

“For SEAT, privacy matter is part of our core business. We design and make cars and mobility products that process big data to make your life enjoyable, making it possible to enjoy SEAT experience at the highest level. We give you control at any time over your information and data, so that you, and only you, decide what to share, when to share, and who you share with. It’s a big value still our essence”.

This Privacy Policy describes how SEAT processes your personal data in the context of www.seat.com and the utilisation and applications offered therein, as well as with respect to other data processing that may be carried out by SEAT in its interaction or relationship with you. Separate data protection or privacy notices may apply to other websites, Apps, products, and services of SEAT.

We inform you that when you purchase a SEAT brand vehicle at a dealership or you go to the after-sales official services, each of these entities, as independent entities, will be responsible for the processing of the personal data that you provide to them. Additionally, SEAT will be responsible, as the manufacturer and guarantor of the vehicle purchased for the purposes derived from the warranty and responsibilities of the vehicle, or for those products and/or services that it supplies to you directly.

1.     Who is the data controller of your personal data?

2.     What types of data do we process?

 Within the functionalities, products and services offered by SEAT, and subject to the purposes set out in this Policy, at SEAT we process the following categories of personal data, without limitation:

• Your identification data and your contact details.
• Your data related to your navigation on the web.
• Identification data of your vehicle.
• Data derived from your identity and digital account; in case you have created one.

3.     How do we use your personal data and what is the lawful basis for processing them?

At SEAT we process the personal data you provide us with, as well as those that derive from your relationship with us, for the following purposes set out below:

4.     How long will we keep your data?

SEAT will process your personal data for the time necessary to fulfil the purpose for which it was collected, and in any case, in general, for a maximum period of 10 years for the purposes based on your consent, as well as for those from which legal liabilities may arise in relation to the vehicle or other product or service sold.

Specifically, for personal data that you have provided only as an interested party in a SEAT vehicle, as a participant in an event, survey or study of the brand or through the contact forms and Call Center, a maximum retention period of 3 years will apply.

As soon as the above purposes are extinguished, your personal data will be blocked, as a general rule, for a period of 3 years. After this period, your personal data will be permanently deleted.

5.     Which recipients will the data be disclosed to?

SEAT will disclose your personal data to other third parties when such disclosure is laid down by law. On the other hand, we want to inform you that SEAT will give access to data to Volkswagen Group companies and other third parties acting them as data processors for the purpose of offering our product and services (e.g., SEAT CONNECT, SEAT ID). Likewise, in order to provide you with the services described above, we require the support of service providers. These third parties may have access to your data and will act in our name and on our behalf, following our instructions, and in no case will they have access to your data for their own purposes.

In certain cases, SEAT, as the approved manufacturer of the vehicle, will be also obliged, at the request of the competent authorities, to process and communicate certain data stored in the vehicle related to the vehicle owner. Some of these obligations may derive from the investigation of crimes, traffic accidents, control of second-hand sales, etc. In this way, data on the operation, use, control, condition, and technical data of the vehicle associated with its VIN may be communicated, such as, for example: mileage, speed, acceleration, navigation control, seat belt condition, environmental conditions, battery condition, liquids, and pressures, etc. The processing and communication of data to the Authorities is covered in compliance with a legal obligation (Art. 6. 1 c) General Data Protection Regulation) of SEAT, as manufacturer of the vehicle.

Additionally, SEAT will disclose your personal data to your Importer or Service Partner of your country for fulfil with your request on the “Contact Us Form with the purpose of contacting you and answer your requests. If your Importer or Service Partner is located outside the EU, this might involve a necessary international transfer of your data. SEAT may also disclose some identification data to the importer in your country for internal administrative purposes such as assigning bonuses to the dealer network or to ensure the proper handling of the customer in the individual countries.

Additionally, we may disclose your data to the Importer of your country with market research and, only in case you have previously consented, for marketing purposes. This will allow the Importer to send you information about its products and services offered. If you want to exercise your rights in relation to this disclosure, you must lead to the Importer since he is considered the data controller.

In relation to the whistle-blower system, your personal data will only be accessed by third parties to whom SEAT is legally or contractually obliged to provide it, as well as by companies in the legal sector and the Volkswagen Group to whom SEAT has entrusted the provision of consultancy and advisory services in connection with the management of the channel, on behalf of SEAT, to the extent necessary for the provision of those services. In those cases, in which it is strictly necessary, disclosure may be made to third parties such as State Security Forces and Corps, Judges and/or Courts, when it is necessary for the correct investigation of the reported facts and/or for the adoption of disciplinary measures or for the processing of the legal proceedings that, where appropriate, may be necessary.

We are assisted in processing your requests, providing Customer Care and advertising by Teleperformance Group Europe, Middle East and Africa SAS (France) and Salesforce.com EMEA Limited (United Kingdom) as processors with a cloud operated within the European Union.

When processing your requests and for the purposes of Customer Care and analysing your data for the purposes of quality assurance and improving Customer Care and our products and services, we are assisted by Amazon Web Services EMEA SARL (Ireland) as a data processor with the cloud operated within the European Union. Recordings for the purposes of improving Customer Care are transcribed using the transcription software ‘Amazon Transcribe’.

6.     Are your personal data be sent outside the EU?

In general, your data will be processed within the European Economic Area. However, some of our suppliers may process your data outside the European Economic Area, such as, for example, Salesforce.com, Inc. which provides our virtual infrastructure on a "cloud computing" model. This entity is stablished in the United States of America. SEAT regulates in accordance with the applicable regulations the relationship with these suppliers in order to ensure and maintain the adequate level of protection in accordance with European standards so that, in the event that the country receiving the data is not considered adequate level, it will regulate the relationship with the third-party recipient through the corresponding Standard Contractual Clauses adapted by the European Commission whose content can be consulted in European Commission official website and also in this link.

7.     What are your rights?

8.     How can you exercise your rights?

You can exercise these rights by sending an email to customercare@seat.es. In the event of reasonable doubt as to your identity, you may be asked for any additional information necessary to confirm your identity.  In case of services that you have log in through SEAT ID, such as Private Area, you can also manage your data and privacy settings through your SEAT ID account at https://seatid.vwgroup.io/.

The exercise of these rights is free of charge unless of manifestly unfounded or excessive requests.

If you wish to assert your data protection rights before the Entity’s Importer or their Dealer and Service Partner networks, please contact them directly.

Finally, if you consider that SEAT has not processed your personal data in accordance with the applicable regulations, you can lodge a complaint with the relevant supervisory authority.

9.     DPO Contact:

If you have any doubts about data protection or wish to get in touch with our data protection officer (“DPO”), you can also contact him by sending an email to dataprotection@seat.es.

June 2023

If you consider that SEAT has not processed your personal data in accordance with the applicable regulations, you can file a complaint with the competent control authority through the website www.aepd.es.