Who is the data controller of your personal data?
|Data controller identity:||SEAT, S.A., with TAX ID A-28049161|
|Address:||Autovía A-2, Km. 585, Martorell, Barcelona (Spain)|
|Data Protection Officer Contact Details:||firstname.lastname@example.org|
How do we use your personal data and what is the lawful basis for processing your personal data?
SEAT, S.A. (hereinafter, ‘SEAT’) will process the personal data by your provided, as well as other personal data that SEAT may have access through the use of the following forms with the purposes specified in each case:
1. Contact Us form: Manage your request and contact you to fulfill your specific request/enquiry/claim.
In relation to the “Contact us form” located in the fleet section, the main purpose is to manage your request in order to provide with information about our products and services.
The legal basis for the processing of your personal data through these forms is your consent as the data subject. You may withdraw this consent in any time without affecting the lawfulness of processing based on consent before its withdrawal.
2. Diesel form: Manage your request for verifying if your vehicle is an affected Volkswagen diesel engine.
The legal basis for the processing of your personal data is your consent as the data subject. You may withdraw this consent in any time without affecting the lawfulness of processing based on consent before its withdrawal.
3. Whistleblower System: Handling your complaints that you have filed through the Whistleblowing channel and adopting the disciplinary or legal measures applicable to each case.
The processing is necessary for compliance with the legal obligation to resolve any queries made pursuant to the Spanish Criminal Code (Organic Act nº 10/1995), of 23 November, as well as SEAT's legitimate interest in preventing, investigating and controlling criminal offences and infringements included in its Code of Conduct.
The processing of your personal data is strictly necessary to manage your request or in order to comply with the aforementioned legal obligations.
Under no circumstances will SEAT carry out automated decisions based on the submitted data.
What other recipients will the data be disclosed to?
For the “Contact Us forms” located in the fleet section and the “Dieselform”, in order to manage your request, SEAT will communicate your personal data to the Importer in your country or to your SEAT SERVICE with the purpose of contacting you and answer your requests. If your Importer or SEAT SERVICE is located outside the EU, this might involve a necessary international transfer of your data. In relation to the contact us form, where necessary, your data can also be disclosed to the Importer or the SEAT SERIVE in your country.
Likewise, SEAT requires the support of service providers. These third parties may have access to your data, but they always be acting in name and on our behalf, following our instructions, and in no case will they process your data for their own purposes.
On the other hand, in relation to the whistleblower 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. Under no circumstances will SEAT carry out international transfers of your personal data to third countries or international organizations.
How long do we retain your data?
SEAT will retain your personal data for the time necessary in order to provide you with an answer in regard to your request, while the erasure of your personal data has not been requested by you as well as during the time necessary in order to comply with the legal obligations needed in each case.
Regarding personal data collected in order to comply with the obligation to manage complaints through the Whistleblower System, SEAT will keep your personal data for the time strictly necessary to decide on the appropriateness of initiating an investigation into the alleged facts and, once decided, they will be duly blocked in order to comply with the corresponding legal obligations in each case. In any case, your personal data will be deleted within a maximum period of three months from their introduction in the complaints channel, unless they are kept in order to certify the functioning of SEAT's crime prevention model.
What are your rights as affected individual?
|Access||You can obtain from SEAT confirmation as to whether your personal data are being processed and access to your personal data.|
|Rectification||You can obtain the rectification of inaccurate personal data concerning you. You also have the right to have incomplete personal data completed.|
|Erasure||You may request the deletion of your personal that when, among other reasons, the data is no longer necessary for the purpose that were collected.|
|Objection||You can object to the processing of your personal data. SEAT will no longer process your personal data unless it has compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.|
|Restriction of the processing||
You can request the restriction of the processing of your personal data where one of the following grounds applies:
|Portability||You can receive, in electronic format, the personal data that you have given us and those that have been obtained from your contractual relationship with SEAT, as well as to transmit them to another entity.|
To exercise your rights, you must attach a copy of your ID or another document which proves your identity and clearly indicating the right you want to exercise. You can exercise these rights by sending an email to:
The exercise of these rights is free of charge.
|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.|
In relation to the data collected in the creation of the user account and the activation of the e-Sim card forms, will be considered data controller SEAT, S.A. (hereinafter, “SEAT”) with Tax Identification Number A-28 049 161 and the following contact details Autovía A-2, Km. 585, Martorell (Barcelona) and email address email@example.com. You can contact with the Data Protection Officer though the email address: firstname.lastname@example.org.
Purpose and lawful basis of the processing
SEAT will process the personal data by you provided, as well as other personal data that SEAT may have access through the forms or during the processing of your request, for the following main purposes:
- Create user account Form: create your user account.
The legal basis of this processing of your data is the consent given by you in the create account form.
- Activation e-Sim Card Form: manage the activation of your e-Sim card and ensuring that the process finish successfully. It may be possible to contact you during the processing.
The legal basis of this processing of your data is the consent given by you in the activation e-Sim request.
- Only in case of having consented, to disclose your data to the Importer with marketing purposes. This will allow to the Importer to send you information about the products and services offered by the Importer. If you want to exercise your rights in relation to this disclosure, you must to lead to the Importer since he is considered the data controller.
The legal basis of this processing of your data is the consent given by you.
What other recipients will the data be disclosed to?
SEAT will disclose your personal data to 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 third parties acting them as data processors for the purpose of offering the SEAT CONNECT services.
How long do we retain your personal data?
SEAT will retain your personal data as long as necessary to provide you with the purposes for which they were collected, and, in any event, until you ask for their erasure. Likewise, being the processing based on your consent, you can withdraw your consent in any time so, in case of withdrawal, your personal data will be blocked during three years in order to face up personal data legal obligations.
Additionally, SEAT informs you that, as your identification personal data will be stored in your SEAT ID account, if you ask for the erasure of your data, your personal data will not be erased from your SEAT ID account if you are user of other Apps. However, you can, at any time, manage your data and privacy settings at https://seatid.vwgroup.io/.
In any case, SEAT will retain your data to comply with any legal requirements corresponding to each category of data.
What are your rights as affected individual?
You can exercise the following rights before SEAT in your condition of data subject:
- Access: You can get information if SEAT processes your personal data, as well as consult your personal data included in the SEAT files.
- Rectification: You can modify your personal data when it´s inaccurate as well as complete those that are incomplete.
- Erasure: You may request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes that were collected.
- Objection: You may request your personal information not to be processed. SEAT will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
- Limitation of the processing: You can request the limitation to the processing of your personal data in the following cases:
- While objection of the exactitude of your personal data is being checked;
- When the data processing is illegal, you object the deletion of your data and request the limitation of its use;
- When SEAT does not need to process your data, but you need it for the exercise of defense claims;
- When you have opposed the processing of your personal data for the fulfillment of a mission of public interest or for the satisfaction of a legitimate interest, while it is verified if the legitimate reasons for the processing prevail over yours.
- Portability: You can receive, in electronic format, the personal data that you have given us and those that have been obtained from your contractual relationship with SEAT, as well as to transmit them to another entity.
- EXERCISE OF RIGHTS: You can exercise these rights by sending an email to email@example.com or through your SEAT ID account by managing your data and privacy settings at https://seatid.vwgroup.io/. The exercise of these rights is free of charge unless of manifestly unfounded or excessive requests.
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.