Privacy Policies


EMIL FREY Belgique SA, in charge of the website www.autosphere.be (hereinafter the « Site »), undertakes to ensure that the processing of your personal data carried out from this Site complies with Regulation No. 2016-679 of 27 April 2016 on the protection of personal data (hereinafter the « RGPD »).

EMIL FREY Belgique SA processes personal data concerning you as data controller in the context of the use of its Site.

The purpose of this confidentiality policy is to inform you, in accordance with the RGPD, of our practices concerning the collection, use and sharing of information that you may provide to us when accessing our Site.

You have the right to access, rectify, delete and object to your personal data on legitimate grounds, as well as the right to port such data, by sending a request to rgpd@emilfrey.be or to the following postal address: Rue de Bruxelles 124, 4340 Awans.

This confidentiality policy describes the information that may be collected via the Site and the use that will be made of it. The Site will not process information that can be used to identify the user by name, directly or indirectly, unless the user voluntarily communicates this information by completing the appropriate forms.

EMIL FREY Belgique SA keeps data in accordance with a retention policy set so that data is kept for a period proportionate to the purpose for which it was collected.

This privacy policy may change according to the legal and regulatory context and the doctrine of the Data Protection Authority (DPA).

We take all necessary precautions to ensure that your personal data is processed securely and in compliance with regulations.

Accordingly:

I- DATA CONFIDENTIALITY GUARANTEES

By using our Site, you may be required to transmit Personal Data to us, directly or indirectly, or through the use you make of the Site.

We collect the Personal Data that you provide to us directly or indirectly through your use of our services.

The Personal Data collected may therefore include:


Please note that you can visit our Site without any form of registration.

However, certain services require you to provide certain Personal Data, in particular requests for information about a vehicle or to make an appointment. In these cases, if you choose not to provide the information we request, you may not be able to access certain parts of the Site, and we may not be able to respond to your request.

As regards data collected from other sources, we may also obtain your contact details and other personal information from our subsidiaries and other third parties, including service providers who help us to determine your location to personalise certain services according to your location.

II- WHY DO WE COLLECT YOUR PERSONAL DATA?

We collect and process your Personal Data for the following purposes:


You may also take part in competitions organised by the AUTOSPHERE brand. In such cases, your Personal Data will be used in accordance with the rules of the competition and the provisions relating to Personal Data specific to the competition.

Our Site also has sharing tools enabling you to relay information present on our Site on social networks such as Facebook or Twitter. This relaying of information via third-party sites subjects you to their own data protection policies.

We encourage you to consult their terms of use and personal data protection policies for further information on the use of your Personal Data.

III- ON WHAT LEGAL BASIS DO WE COLLECT YOUR PERSONAL DATA?

We collect and process your Personal Data in compliance with the regulations, and only within the framework of the following legal basis(s):


IV- WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

The Personal Data of our users is strictly confidential and intended exclusively for EMIL FREY Belgique SA and EMIL FREY HOLDING AG.

The Data collected is intended for us in our capacity as Data Controller.
Purposes Recipients of data Departments receiving data
Request for information on vehicles displayed EMIL FREY Belgique SA for lead qualification and transmission to the sales department of the dealership concerned.
To carry out commercial prospecting operations (open house invitations, private sales, information on new models with an invitation to test drive, presentation of the services of the dealerships in the AUTOSPHERE network) Marketing Department of the dealership concerned for targeting and EMIL FREY Belgique SA for implementing the campaign.
Customer satisfaction surveys Quality department of the dealership concerned and the manufacturer's quality department.
Analysis of commercial performance and site usage trends Marketing department of the dealership concerned and EMIL FREY Belgique SA
Request to exercise your RGPD rights Marketing department of the dealership concerned and DPO of EMIL FREY Belgique SA
Receive your comments in order to anticipate possible disputes. Service of the dealership concerned by the potential dispute.
Improve navigation and your experience on the Site EMIL FREY Belgium SA Marketing Department.


V- HOW LONG DO WE KEEP YOUR PERSONAL DATA ?

Your Personal Data will only be kept for as long as is strictly necessary for the purposes set out in this Policy, in accordance with the applicable laws and regulations. After this period, your Personal Data will be deleted.

Purpose of processing Legal basis Retention period Archiving retention period
Requests for information about vehicles on display Mesures précontractuelles prises à votre demande 3 years 3 years
To carry out commercial prospecting operations (open door invitations, private sales, information on new models information on new models with an invitation to test drive, presentation of the dealership's services, events sponsored by the dealership) If by SMS or Mail - you have given your consent. Otherwise, processing necessary for the legitimate interests of the data controller 3 years from the last contact made on your initiative 3 years
Customer satisfaction surveys Processing necessary for the purposes of the legitimate interests of the data controller 3 years from the last contact initiated by you 3 years from the date of termination of the contract
Impact analysis and site usage trends Processing necessary for the purposes of the legitimate interests of the data controller 13 months 13 months
Request to exercise rights RGPD Processing is necessary for compliance with a legal obligation 13 months 13 months
Receive your comments in order to anticipate possible disputes Processing necessary for the purposes of the legitimate interests of the data controller 3 years 3 years
Improve navigation and your experience on the Site Processing necessary for the purposes of the legitimate interests of the data controller 13 months 13 months




VI- NON-DISCLOSURE OF PERSONAL DATA

Your Personal Data will never be sold, shared or communicated to third parties, except as provided for in this privacy policy.

Your Personal Data may also be communicated to third parties acting for us or on our behalf in the context of specific processing in accordance with the purposes for which it was initially collected, or may be legally processed, in accordance with the local regulations in force, in the context of activities such as the provision of services, evaluation of the usefulness of this site, product marketing and sales, data management or technical support.
These third parties have undertaken, by signing a contract, to use your Personal Data only for the purposes agreed, and not to sell or disclose it to other third parties unless required to do so by law, or unless we explicitly authorise them to do so, or unless a provision to this effect is included in this confidentiality policy.

The Personal Information we collect may also be disclosed to a third party if all or part of the business of this Site and associated customer data is sold, assigned or transferred, in which case we will require the buyer and/or transferee to treat such Personal Information in accordance with this Privacy Policy.

In addition, Personal Data may be disclosed to a third party if we are required to do so by any applicable law or regulation, court order or governmental regulation, or if such disclosure is necessary in connection with a criminal investigation or proceeding, whether at home or abroad.


VII - RIGHT OF ACCESS, RECTIFICATION, OPPOSITION, DELETION AND PORTABILITY

Whenever we process Personal Data, we take all reasonable steps to ensure the accuracy and relevance of the data in accordance with the purposes for which we collect it.

You have a right of access and a right to object to the processing of your Personal Data on legitimate grounds, i.e. if such processing is not reasonably necessary for the pursuit of our legitimate interest as described in this Privacy Policy, or for compliance with the law.

In the event of electronic canvassing, we will provide you with the means to withdraw your consent to receive information. You may also request the deletion of your data. This request for deletion will be subject to the obligations imposed on us by law, in particular with regard to the retention and archiving of documents or the performance of the contract. You may also request the portability of your data. This portability is limited to the data you have sent us.

In the event of a request for rectification, you should specify the data you would like us to correct or update by identifying yourself precisely.

We will also implement your requests for deletion of personal data insofar as these do not prevent us from establishing, exercising or defending our rights in the event of a dispute, particularly if we are bound by a contractual relationship.

Similarly, if you wish to know how we use your Personal Data, or if you wish to object to the processing of your Personal Data, please send an e-mail to rgpd@emilfrey.be.

For any problem or question relating to the use of your personal data, you may contact the Data Protection Officer of EMIL FREY Belgique SA:


In addition, you have the right to lodge a complaint with the DPA by filling in a form from the link www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte or by sending an e-mail to the address: contact@apd-gba.be.

VIII- SECURITY AND CONFIDENTIALITY

To ensure the security and confidentiality of the Personal Data we collect, we use private networks protected by encryption devices.

Similarly, the data is hosted in secure Data Centres with high physical and logical protection standards. When processing your Personal Data, we take all reasonable steps to protect it against loss, misuse, unauthorised access, disclosure, alteration or destruction. All our employees likely to process personal data have received specific training to ensure that they comply with the rules laid down by the RGPD and are aware of the care to be taken when processing such data.

IX - TRANSFER OF DATA ABROAD

We are a subsidiary of EMIL FREY HOLDING AG which is part of an international group of Swiss origin with databases in the European Union and Switzerland.

The data is managed by EMIL FREY Belgique SA. Other third parties intervene on behalf of these two subsidiaries. We may have to transfer your data to one of the group's databases outside your country of residence, but always to countries in the European Union or Switzerland for technical reasons (country referenced by the EU as ensuring an adequate level of protection of Personal Data and not requiring specific supervision). Nevertheless, it is possible that your data may be transferred outside the EU as part of the processing carried out by our subcontractors, in particular Google Analytics.

X - Do not call me again - DNCM

If the User no longer wishes to be contacted by telephone on the number they have provided to EMIL FREY Belgique SA, they may at any time register their number on the Do Not Call Me list on the website www.dncm.be or by post by writing to : Do Not Call Me vzw (DNCM vzw) Raketstraat 50, 1130 Brussels.

However, EMIL FREY Belgique SA may contact by telephone the User who has expressly requested this, during a period freely determined by the User or, failing this, within a period of three (3) months from the date of the User's request.

XI- COOKIES
a. What are cookies?
Cookies are pieces of information contained in small text files added to the browser of the User's computer, tablet or mobile phone while they are visiting websites. Cookies are widely used by websites.

They ensure that they function properly or improve browsing, and also provide certain information, particularly in terms of audience measurement, to the owners of these sites. Cookies placed on the Site may include information about users' online preferences and enable the website to be tailored to your centres of interest.

Only the sender of a cookie can read or modify the information contained therein.
b.What information is collected by these cookies?

The data generated by these cookies concerns:


c. How do I accept or refuse the use of cookies?

You are informed that, during your visits to this Site, cookies may be installed on your terminal equipment. On your first visit to our Site, you will be asked to accept or refuse the use of certain cookies.

You have the option of configuring your equipment so that it accepts all cookies, informs you when a cookie is issued or never accepts any cookies.
The latter option means that certain personalised services cannot be provided to you and, as a result, you may not be able to take full advantage of all the functions offered by the Site.

If you do not wish to receive cookies in general or only wish to refuse certain cookies, you can modify the settings of your browser as appropriate.

Instructions for doing so are provided on the website of each browser:


You can also find the necessary information on the Data Protection Authority (DPA) website: www.autoriteprotectiondonnees.be/citoyen.

d. How do we use cookies?

The information collected using cookies helps us to analyse the use of the Site and enables us to offer you a better user experience during your visit. We do not intend to use cookies to deliver personalised advertising messages to children.


e. What types of cookies do we use and for what purposes?
i. Functional cookies

Some cookies are strictly necessary for the use of the Site or certain of its functionalities, such as allowing you to authenticate yourself or to manage your shopping basket.

For your complete information, these cookies are managed by the following service providers:


When you use this Site, these functional cookies cannot be refused.

ii. Session cookies and preference cookies

The Site may use session cookies exclusively to enable the transmission of a communication necessary for its operation, for example to enable the user to browse the Site. These cookies expire at the end of the user's session (i.e. when the user closes the browser window). The Site may also use cookies that are kept for a longer period to remember your preferences and choices on the website only if you accept them by clicking on the "Accept" button provided for this purpose. These cookies will last for a maximum of thirteen (13) months.

iii. Analytical cookies

The Site may use analytical cookies to improve your performance, by collecting only connection data relating to the date, time, Internet address and protocol of your terminal as well as the page consulted. The Site does not re-use this data for other purposes, does not cross-check it with other processing, including customer files, and does not keep it in any way for longer than six (6) months. If you have consented, the Site uses Google Analytics tools and associated cookies.

Although we have no control over this supplier of analytical tools, which is responsible for its own processing, or over the data it collects, including in the context of a transfer of data outside the European Union if it is located in the United States, we felt it essential to mention this so that you have clear and complete information about the fact that their use may, where appropriate, require you to give your consent.

For further information, and subject to the availability of this information in French, please refer to the Google Analytics website: click here to consult the Google Analytics privacy policy. However, you may object to these various operations by configuring your browser, such as Edge or Firefox, by following the instructions, also indicated above, which are provided for this purpose on the browser's website or, failing that, on that of the Data Protection Authority (DPA).If you exercise your right to object, the Site confirms that no connection data will be transmitted to any supplier of audience analysis tools. Finally, you have a right of access to the data concerning you which you may exercise by contacting the supplier concerned, specifying the identification number of the cookie which will be allocated to you by the latter.


For your complete information, these cookies are managed by the following service providers:
iv. Advertising cookies

If you have given your consent, the Site may use advertising cookies to enable us to provide you with offers and services that are closest to your interests and preferences.

The Site does not transfer any of this data to third parties outside companies belonging to EMIL FREY HOLDING AG, does not re-use it for other purposes, and does not keep it in any way for a period longer than thirteen (13) months.

For your complete information, our partners are as follows:

Explanations will be included in each advertising email so that you can stop the sending of advertisements to you at any time.

v. Social network sharing cookies

The Site offers features that enable you to share some of the content published on the Site via social networking sites. This is particularly the case with the "Share" and "Like" buttons from social networks such as "Facebook", "Twitter", "Instagram", "Snapchat", "Tik Tok", "YouTube", etc.

This functionality is based on cookies and similar technologies issued and managed by the publisher of the social network concerned. These cookies and similar technologies are deposited in your terminal, if you accept them, when you browse the Site.

EMIL FREY Belgique SA has no control over the process used by third-party applications included on the Site and by social networks to collect information relating to browsing on the Site and associated with the personal data they hold.

EMIL FREY Belgique SA therefore invites the User to consult the privacy protection policies of these third parties in order to become aware of the purposes of use, in particular advertising, of the browsing information that they may collect through these third-party applications. These protection policies must enable Users to exercise their choices with regard to these third parties, in particular by configuring the user accounts held by the User with these third parties.

For more information on the type of data collected by social networks, please use the following links:

https://fr-fr.facebook.com/policies/cookies/
https://help.twitter.com/fr/rules-and-policies/twitter-cookies