Privacy Policy

1. Proposed inclusions to the SEAT Privacy Policy (to be included at the start of the Policy):

Scope

This privacy policy is applicable to all customers’ personal data held by Continental Cars Limited (hereinafter “Continental Cars”) and SEAT S.A. (hereinafter “SEAT”) and outlines how personal information is collected, used and processed by Continental Cars and SEAT.

What is Personal Data?

Personal Data means any information which identifies a particular individual or that which relates to an identifiable individual whether directly or indirectly. Every identified or identifiable individual is called a Data Subject.

Personal Data is collected in various ways, chiefly when you choose to provide us with your personal data through the local SEAT dealership website or at any sales point/showroom of the local SEAT dealership represented by Continental Cars in Malta to benefit from one or more of our Services and/or Products on offer.

SEAT and Continental Cars are committed to protect your privacy and the security of Your Personal Data at all times.

Purpose for Processing

SEAT and Continental Cars will only process the personal data collected directly from you or from external sources when we have a lawful basis to process your personal data, in accordance with the EU General Data Protection Regulation (‘GDPR’). We might need to collect your personal data to keep you informed about our products and services, when you purchase our cars or products or request/book our services We will process your personal information for the following purposes and lawful reasons:

• When we need to process your personal data to enter into and maintain a contractual agreement we have with you chiefly to provide you with the appropriate products and services and communicate our policies and terms and conditions;
• When we need to process your personal data in order to comply with our legal obligations arising principally from Maltese and/or European Union Legislation;
• When we need to process any requests submitted by you through this local dealership website including requests for quotations and for test-drives.
• When we have your explicit consent to process your personal data for a specific purpose. We will always ask for your consent to send you direct marketing material if you are not an existing SEAT and/or Continental Cars customer.

2. Proposed amendments to the existing local SEAT Privacy Policy (following the clauses introduced above):

Other Purposes for Processing

SEAT and Continental Cars will also process your personal data for the purpose of handling your complaints 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.

SEAT and Continental Cars will also be processing your personal data if it is strictly necessary to manage this communication and to comply with the afore-mentioned legal obligations. Under no circumstances will SEAT and/or Continental Cars carry out automated decisions based on the submitted data.

For how long we keep your personal data

We shall keep your personal data for as long as it is needed it to provide the products and services you have contracted to. We may also keep it to comply with our legal obligations, respond to queries and resolve any disputes. The criteria we use to determine data retention periods include applicable contractual provisions that are actually in force, legal statutory limitation periods, applicable regulatory requirements and industry standards.

SEAT will only 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.

Who we share your Personal Data with

Your personal data will only be accessed by third parties to whom SEAT and Continental Cars are 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 and/or Continental Cars, to the extent necessary for the provision of those services. Under no circumstances will SEAT and/or Continental Cars carry out international transfers of your personal data to third countries or international organizations.

Data Subject Rights and Data Protection Officer

The Data Subject has a number or rights. You may exercise your rights of access, rectification or erasure, as well as restrict the processing of your data, object to its processing, or request the portability of your data by writing an e-mail to the SEAT Data Protection Officer transparencia@seat.es, or to the Continental Cars Data Protection Officer dpo@mizzi.com.mt attaching a copy of your ID or any other document that proves your identity and clearly indicating the right you want to exercise. In the event that you are not satisfied with the attention received after exercising any of the aforementioned rights, you may submit a claim to the Spanish Data Protection Agency or to the Maltese Office of the Information and Data Protection Commissioner (IDPC).