Privacy Policy

Privacy Policy - CarToGo Europe | Effective from March 10, 2024

Hello and welcome to the privacy policy (the “Policy”) of NextHub Digital SA, Sole Proprietor of CarToGo (the “Platform”), which allows users to compare and view the technical features of vehicles available on the market, offering the opportunity to receive personalized quotes for purchase or book a test drive.

CarToGo operates as a tool to provide users with detailed and comparable information about vehicles, enabling them to: (i) easily access technical specifications, features, prices, and details of various vehicles on the market; (ii) obtain personalized quotes tailored to their needs; (iii) request contact to organize test drives with the best offers available for their models of interest.

Through the Platform, we collect some information about you, as a User (“you” or the “User”), which qualifies as “Personal Data.” Personal Data is defined as any information that relates to identified or identifiable individuals through an identification code or other information – for example: name and surname; email address; phone number; postal code.

This Policy aims to provide you with all the necessary information to understand how we collect, use, and disclose your Personal Data in the context of your experience on CarToGo.

Collection and Use of Personal Data 

CarToGo collects only the following personal data, voluntarily provided through the contact form available on the website pages: 

• First Name
• Last Name
• Email
• Phone Number
• Postal Code 

These data are used solely to allow third-party clients of NextHub Digital SA to contact you with personalized offers and create specific quotes for the vehicles of your interest, as well as to organize personalized test drives.

Changes to this Policy 

NextHub Digital SA reserves the right to modify this Policy to align with current regulations or to introduce technical and organizational updates to the Platform. Any changes will be communicated through this page, with an updated revision date. We encourage you to regularly check this section to stay informed about any changes.

The changes will be effective from the date of publication and binding for all users of the Platform. In the case of changes related to consent-based processing, your consent will be requested again where necessary.

1. Data Controller, Staff, and Data Protection Officer The Data Controller is NextHub Digital SA, Sole Proprietor of CarToGo (the “Platform”), which allows users to compare and view technical features of vehicles available on the market, offering the opportunity to receive personalized quotes for purchase or book a test drive. For any information or requests, you can contact us at privacy@nexthubdigital.com.
2. Types of Data Processed and Purposes of Processing
   
   

2.1 Browsing Data and Activity

While using the Platform, IT systems may automatically acquire certain information related to your browsing, such as:

• IP Address
• Number of accesses
• Browsing duration
• Browser used
• Pages viewed
• Date and time of access

These data are collected mainly to:

• Obtain anonymous statistical information on the use of the Platform.
• Ensure the proper functioning of the website.
  
  

2.1.1 Cookies

The Platform uses different types of Cookies to enhance the user experience and ensure the proper functioning of the services offered. The Cookies used are: 

• Necessary Cookies: These Cookies are essential for the operation of the Platform and allow the use of essential features, such as accessing restricted areas of the site. Without these Cookies, certain requested services cannot be provided.
• Functional Cookies: These Cookies improve the user experience by remembering, for example, selected preferences or customizing the content.
• Analytics Cookies: Used to collect anonymous data on the pages visited and analyze user behavior to optimize the Platform and improve search results.
• Marketing Cookies: These Cookies allow the Platform to offer targeted and personalized advertisements based on the user’s interests.

Users can manage Cookie preferences through the settings of the browser used or via the management tools provided by the Platform.

2.1.2. Browser Notifications

The platform also provides the option to accept or decline receiving offers and updates in the automotive sector via web browser notifications. These notifications function solely as push notifications sent to the user's desktop or mobile device, without collecting additional data or triggering other processes. Enabling notifications requires the user's explicit consent, which can be managed or revoked at any time through the browser settings.

2.2 User-Provided Data

When you fill out the contact form on the Platform, the following data will be requested:

• First Name
• Last Name
• Email
• Phone Number
• Postal Code

These data are used to:

• Provide personalized quotes for the vehicles of your interest.
• Enable NextHub Digital SA or its third-party clients to contact you to organize test drives or offer advantageous deals.

2.3 Voluntarily Provided Personal Data

The Personal Data you voluntarily and freely provide (e.g., via email to the addresses indicated on the Platform for obtaining information) will be acquired and processed by NextHub Digital SA as the Data Controller. Specifically, in addition to your email address, which is necessary to respond to you, any other personal data you reference or include in your communication will be acquired. These Personal Data will not be disclosed or communicated to third parties outside the organization of [OWNER NAME] or used for commercial or advertising purposes. They will be retained solely for purposes related to managing correspondence.

2.4 Geolocation

The acquisition of your location data is possible only with your express consent during the use of the Platform. These data may be used to: 

• Provide you with personalized services and/or advertisements available in your geographical area.

You can deactivate the geolocation function at any time from your account settings on the Platform or directly from your device settings.

• Legal Basis: The processing of your geolocation data is based on your explicit consent and our legitimate interest in personalizing the services offered based on your geographic area.

2.5 Protection of Personal Data

CarToGo uses advanced encryption technologies to protect the integrity and confidentiality of your Personal Data. Data are stored on an architecture that includes daily backups. Additionally, in the event of data transfer with your consent, sensitive data are encrypted using advanced algorithms such as AES, MD5, or SHA2.

Categories of Recipients to Whom Personal Data May Be Disclosed

Your Personal Data may be disclosed exclusively to: 

• Internal/external consultants or collaborators to ensure compliance with current regulations or to perform contractual services; 
• Judicial authorities or other public authorities to fulfill legal obligations.
• With your explicit consent, your Personal Data may be transmitted to third-party companies, our commercial partners, for advertising and commercial purposes. These companies act as independent Data Controllers and assume responsibility for compliance with data protection regulations.

Processing Methods

Your Personal Data are processed lawfully and fairly through automated or semi-automated tools to ensure their security and integrity.

Optional Nature of Data Provision

Except in cases where Personal Data are necessary for the use of requested services, the provision of other data is optional and does not affect the use of the Platform.

Data Retention Period

Your Personal Data will be retained only for the time necessary to fulfill the purposes for which they were collected, in compliance with applicable regulations. For marketing activities, data will be retained for a maximum of 36 months, while for profiling purposes, the maximum retention period is 12 months.

Rights of Data Subjects

You have the right to request details about the Personal Data we process, withdraw previously granted consent to their processing, correct or delete them, and opt out of being contacted if you have not requested it.

(i) Right of Access to Your Personal Data

You can request access to your Personal Data by contacting us through the provided contact details. Typically, data will be made available within 10 days, but no later than 30 days. In some cases, we may not be able to provide access, such as if this would compromise the privacy or security of others. In such cases, we will provide a formal explanation.

Administrative costs will be communicated in advance and will require your consent. If you request a copy of the data electronically, we will provide them in electronic format unless otherwise requested.

(ii) Right to Modify or Delete Your Personal Data

If you have an account, you can access it to modify or delete your Personal Data. Alternatively, you can send a request to privacy@nexthubdigital.com. In case of difficulty, you can contact us through the same email address, and we will do our best to resolve the issue promptly.

In case of exercising the right to erasure, we will inform our commercial partners and other entities to whom Personal Data have been communicated.

(iii) Right to Object to the Processing of Your Personal Data

You have the right to request the interruption of the processing of your Personal Data, even if necessary for our legitimate interests, such as for commercial purposes or to send you personalized offers. You can object to processing for advertising purposes at any time.

If you have consented to receive offers from commercial partners, they will be responsible for managing your rights, including the right to opt-out. You can manage your preferences directly from your account. Once your request is processed, we will stop sharing your data with commercial partners.

(iv) Right to Data Portability

You have the right to request that your Personal Data, processed based on your consent or a contract, be provided in a structured, commonly used, and machine-readable format, and, where technically feasible, transmitted directly to another organization.

(v) Right to Lodge a Complaint

If you believe your rights have been violated, you can lodge a complaint with the local Data Protection Authority in your country of residence within the European Economic Area (EEA). A list of authorities is available in the Privacy Policy.

Physical Location of Personal Data

Your Personal Data are stored within the EEA on servers located in the Netherlands, Germany, and France. However, they may be transferred and processed in countries outside the EEA that ensure an adequate level of data protection, as assessed by the European Commission. We ensure that your data are processed securely, in compliance with applicable regulations, using, where necessary, European standard contractual clauses or equivalent measures.

How to Contact Us?

For questions, requests to cease processing, or copies of your Personal Data, you can contact us at privacy@nexthubdigital.com. Remember to include your address for a response.

The data controller is NextHub Digital SA, headquartered in Zurich, Switzerland, Postal Code 8032, Kreuzplatz 2.