This Privacy Notice provides information on how Maxomotive Schweiz AG and its group and subsidiary companies (SsangYong Schweiz AG, Astara Mobility Switzerland AG, Astara Ital Switzerland AG) as well as its partners (hereinafter individually or collectively: “ASTARA”, “we” or “us”) as representatives of the brands Nissan, Hyundai, Fiat, Fiat Professional, Alfa Romeo, Jeep, Abarth as well as SsangYong, Maxus and Aiways collect and process personal data concerning you or also other persons (so-called “third parties”). We use the word «data» here interchangeably with «personal data».
A list of these subsidiaries and group companies can be found here https://astara.com/who-we-are.
«Personal data» means data relating to identified or identifiable individuals, which means that the relevant data, in combination with additional data, make it possible to draw conclusions about the identity of these individuals. «Sensitive personal data» is a subset of personal data that is specially protected under applicable data protection law. This includes, for example, data revealing racial or ethnic origin, health data, religious or philosophical beliefs, biometric data for identification purposes, and information relating to trade union membership. In Section 3, you will find information about the data we process in accordance with this Privacy Notice. «Processing» means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.
The protection of your privacy and your personal data is extremely important to us. You will find information in this Privacy Notice about what we do with your data when you use www.aiways-switzerland.ch, our other websites or apps (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. This information is not an exhaustive description, as other documents (e.g. general terms and conditions, terms and conditions of participation, privacy notices from our brand partners, etc.) may govern other specific matters that may be relevant to the additions or adaptations to this Privacy Notice, wherein we inform you of additional processing activities not mentioned in this Privacy Notice.
If you provide us with personal data of other persons (e.g. family members, work colleagues, etc.), please make sure that these persons are aware of this Privacy Notice and only share their personal data with us if you are allowed to do so and if this personal data is correct. By submitting data via third parties, you confirm this.
This Privacy Notice is aligned with the requirements of the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA», considering the revision). However, the application of these laws depends on each individual case.
In the event of any inaccuracies and/or discrepancies between the various language versions of this Privacy Notice, the German version shall prevail. The English translation is for information purposes only and has no legal value.
Maxomotive Schweiz AG, Dietlikon, Switzerland (“Astara”) is responsible for the data processing described here, unless otherwise specified or communicated in individual cases, for example in additional privacy notices, on a form or in a contract. However, unless we tell you otherwise, this Privacy Notice also applies where a group company of the Astara group is the controller, instead of Astara. This applies, in particular, where your data is processed by a group company in connection with its own legal obligations or contracts or where you share data with such a group company. In these cases, this group company is the controller and only if it shares your data with other group companies for their own processing (see section 7), will these other group companies also become controllers.
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For each processing activity there are one or several parties that are responsible for ensuring that the processing complies with data protection law. This party is called the controller. It is responsible, for example, for responding to access requests (Section 11) or for ensuring that personal data is processed securely and not used in an unlawful manner.
Additional parties may be joint controllers for the processing set out in this Privacy Notice if they participate in determining the purpose or means of the processing. All group companies may act as joint controllers. If you wish to receive information about the controllers for a specific processing activity, you are welcome to ask us as part of your access right (Section 11). Astara remains your primary contact, even if there are other joint controllers.
In Section 3, Section 7 and Section 12, you will find additional information about third parties with whom we work together and who are controllers for their processing. If you have any questions for these third parties or if you wish to exercise your rights, please contact them directly.
If you have any questions regarding the handling of your data or for exercising your rights under Section 11 you can reach us as follows:
Maxomotive Schweiz AG
Brandbachstrasse 6
CH-8305 Dietlikon
privacy.ch@astara.com
Our representative and our Data Protection Officer in the European Economic Area in accordance with Article 27 of the GDPR is: ASTARA MOBILITY, Avenida de Bruselas 32, 28108 Alcobendas (Madrid) or by email corporate.communications@astara.com or privacy.es@astara.com
We process various categories of data about you. The main categories of data are the following:
Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This can help us to provide an appropriate layout of the website or to show you a website customized for your region, for example. We know through which provider you access our offerings (and therefore also the region) because of the IP address, but usually this does not tell us who you are. However, this changes for example when you create a user account, because personal data can then be linked with technical data (for example, we can know the browser you use to access an account through our website). Examples of technical data include protocols («logs») that are created in our systems (for example the log of user logins to our website).
Registration data includes the information you provide when you create an account on our website (for example username, password, name, e-mail). It also includes the data that we may require from you before you can use certain free services, such as, for example, our WLAN service, in this case: Name, e-mail and telephone number; or the redemption of vouchers, in this case: Name, address, contact details, time of redemption. You must also register if you wish to subscribe to our newsletter. In relation to access controls, we may need to register you with your data (access codes in badges, biometric data for identification) (see the category «other data»).
Communication data is your name and contact details (e.g. address, e-mail address, phone number, etc.), the means, place and time of communication and usually also its content (i.e. the content of e-mails, letters, chats, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID document number or a password set by you.
Master data includes data such as name, address, e-mail address, telephone number and other contact details, gender, date of birth, nationality, data about related persons, websites, social media profiles, photos and videos, copies of ID cards; moreover, details of your relationship with us (customer, supplier, visitor, service recipient, etc.), details of your status, allocations, classifications and mailing lists, details of our interactions with you (if applicable, a history thereof with corresponding entries, customer appointments), vehicle details (e.g. make, model, license plate number, mileage, replacement vehicle, chassis number, date of placing on the market, etc.), reports (for example from the media), or official documents (for example Vehicle or driver’s license statements, excerpts from the commercial register, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number and credit card data. Declarations of consent and opt-out information are also part of the master data, as well as information about third parties, for example contact persons, recipients of services, advertising recipients or representatives.
In relation to contact persons and representatives of our customers, suppliers and partners, master data includes, for example, name and address, information about the role or function in the company, qualifications and (where applicable) information about superiors, co-workers and subordinates and information about interactions with these persons.
Master data is not collected comprehensively for all contacts. The data collected in an individual case depends mostly on the purpose of the processing activity.
Contract data includes information about the conclusion of the contract, about your contracts (such as purchase, financing, leasing or car subscription contracts), for example, the type and date of conclusion, information from the application process (such as the application for the performance of our products or services) and information about the relevant contract (for example its duration) and the performance and administration of the contracts (for example information related to billing, customer service, technical assistance and enforcement of contractual claims). Contract data also includes information about deficiencies, complaints and changes to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contract data also includes financial data, such as credit information (meaning information that allows us to draw conclusions about the likelihood that receivables will be paid), information about reminders and debt collection. We receive this data partly from you (for example when you make payments), but also from credit agencies and debt collection companies and from public sources (for example a commercial register).
Behavioral data is information about certain actions, such as your response to electronic communications (for example if and when you have opened an e-mail) or your location, as well as your interaction with our social media pages and your participation in sweepstakes, competitions and similar events. For example, we may collect your location data wirelessly through unique codes that your cell phone emits or when you use our website. We will use signage at the relevant locations to tell you about the collection of anonymous motion profiles, and we will only create personalized motion profiles with your consent.
Preference data tells us what your needs are, which products or services might be of interest to you or when and how you will likely respond to messages from us. We obtain this information from the analysis of existing data, such as behavioral data, so that we can get to know you better, tailor our advice and offers more precisely to you and generally improve our offers. To improve the quality of our analyses, we may combine this data with other data that we also obtain from third parties, such as address dealers, administrative offices and publicly available sources such as the Internet, for example with information about your household size, income bracket and purchasing power, shopping behavior, contact data of relatives, and anonymous information from statistical offices.
Behavioral and preference data may be analyzed on a personally identifiable basis (for example to show you personalized advertising), but also on a non-identifiable basis (for example for market research or product development). Behavioral and preference data may also be combined with other data (for example, motion data may be used for contact tracing as part of a health protection concept).
Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in relation to contracts, when you use the website, etc.). You are not obliged or required to disclose data to us except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.
We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services or has accepted an invitation to an event, because it is a technical requirement or because we wish to communicate with you. If you or the person you represent (for example your employer) wishes to enter into or perform a contract with us, we must collect master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offerings for this purpose. If you do not provide us with the data necessary for the conclusion and performance of the contract, you should expect that we may refuse to conclude the contract, that you may commit a breach of contract or that we will not perform the contract. Similarly, we can only submit a response to a request from you if we process communication data and – if you communicate with us online – possibly also technical data. Also, the use of our website is not possible without us receiving technical data.
As far as it is not unlawful we also collect data from public sources (for example debt collection registers, land registers, commercial registers, the media, or the internet including social media) or receive data from other companies within our group, from public authorities and from other third parties (such as credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).
The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we receive in relation to administrative and legal proceedings, information in relation to your professional functions and activities (so that we can, for example, conclude and process transactions with your employer with your assistance), information about you in correspondence and meetings with third parties, credit information (where we conduct business with you in a personal capacity), information about you that persons related to you (family members, advisors, legal representatives, etc.) share with us so that we can conclude or perform contracts with you or involving you (for example references, your delivery address, powers of attorney, information about compliance with legal requirements such as those relating to fraud prevention and the combating of money laundering and terrorist financing, export restrictions, information from banks, insurance companies, sales and other contractual partners of us about your use or provision of services (for example payments, purchases, etc.), information from the media and the internet about the use or provision of services by you (for example payments made, purchases made, etc.), information from the media and the internet about you (where appropriate in a specific case, for example in the context of an application, marketing/sales, press review, etc.), your address and potentially interests and other socio-demographic data (especially for marketing and research purposes) and data in relation to the use of third-party websites and online offerings where such use can be linked to you.
We process your data for the purposes explained below. Further information is set out in Sections 12 and 13 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.
We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 11) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data and master data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.
The above includes all purposes in relation to which we communicate with you, whether in the context of customer service or consulting, authentication in case the website is used, and for training and quality assurance (for example in customer service). We further process communication data to enable us to communicate with you by e-mail and telephone, as well as through text message, messenger services, chats, social media, and by letter and fax. Communication with you usually takes place in relation to other processing purposes, for example so that we can provide services or respond to an access request. Our processing also serves to document the communication and its content.
We process data for the conclusion, administration and performance of contractual relationships.
We conclude various contracts with our business and private customers, suppliers, subcontractors and other parties, such as partners in projects or parties in legal proceedings. In particular, we process master data, contract data and communication data and, depending on the circumstances, registration data relating to the customer or the persons for whose benefit the customer has received a service. This includes, for example, the recipients of our products or services, who receive related vouchers and invitations from our own customers and can become our customers when redeeming them. In this case, we process data in order to perform the contract with these recipients, but also with the contractual partners who have invited them.
In the run-up of a business relationship, personal data – in particular master data, contract data and communication data – is collected from potential customers or other contractual partners (for example in an order form or a contract) or results from a communication. In connection with the conclusion of a contract, we process data to assess creditworthiness and to start a customer relationship. In some cases, this information is reviewed in order to comply with legal requirements.
As part of performing contractual relationships, we process data for the administration of the customer relationship, to provide and claim contractual services (which includes involving third parties, such as logistics companies, security service providers, advertising service providers, banks, insurance companies or credit information providers, who may in turn provide data to us), for consulting and for customer support. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the performance, as are accounting, termination of contracts and public communication.
We process data for marketing purposes and relationship management, for example to send our customers and other contractual partners personalized advertising for products and services from us and from third parties (for example from advertising partners). This may happen in the form of newsletters and other regular contacts (electronically, by e-mail or by telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, contests, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes. With your consent, we can target our online advertising on the internet more specifically to you (see Section 12). Finally, we also wish to enable our contractual partners to contact our customers and other contractual partners for marketing purposes (see Section 7).
For example, if you consent we may send you information, advertising and product offers from us and from third parties within and outside the group (for example advertising partners), as printed material, electronically or by telephone. For this purpose, we process in particular communication and registration data. As most companies, we personalize communications so that we can provide you with customized information and offers that meet your needs and interests. Therefore, we combine data we process about you and collect preference data and use this data as a basis for personalization (see Section 3). We also process data in relation to contests, competitions and similar events.
Relationship management includes addressing existing customers and their contacts, possibly personalized on the basis of behavioral and preference data. In the context of relationship management, we may also operate a customer relationship management system («CRM») in which we keep the data of customers, suppliers and other business partners that is required for relationship management, for example data about contact persons, relationship history (for example information about products and services purchased or supplied, interactions, etc.), interests, marketing measures (newsletters, invitations to events, etc.) and other information.
All this processing is important to us not only to promote our offerings as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships, and to use our resources as efficiently as possible.
We further process your data for market research, to improve our services and operations, and for product development.
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We strive to continuously improve our products and services (including our website) and to respond quickly to changing needs. We therefore analyze, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details, see Section 12). This helps us understand the market acceptance of existing products and services and the market potential of new products and services. To this end, we process in particular master data, behavioral data and preference data, but also communication data and information from customer surveys, polls and studies and other information, for example from the media, social media, the Internet and other public sources. We use pseudonymized or anonymized data for these purposes to the extent possible. We may also use media monitoring services or conduct media monitoring ourselves and process personal data in order to conduct media monitoring or to understand and respond to current developments and trends.
We use anonymized location data, for example, to provide our contractual partners with recommendations for avoiding rush hours. With your prior consent, we use non-anonymized location data to point out interesting offers and products to you in the vicinity based on your position, to infer your interests from the position data (dwell time) and to inform you of which products and services other contractual partners with similar interests have used.
We may also process your data for security and access control purposes.
We continuously review and improve the appropriate security of our IT and other infrastructure (for example buildings). Like all companies, we cannot exclude data security breaches with absolute certainty, but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and IT infrastructures, for system and error checks, for documentation purposes and in the context of backups. Access controls include electronic system access controls (for example logging into user accounts), as well as physical access controls (for example building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations («Compliance»).
This includes, for example, the implementation of health security concepts or the regulated fight against money laundering and terrorist financing. In certain cases, we may also be required to make certain clarifications about our customers («Know Your Customer») or to report to the authorities. Disclosure and information or reporting obligations, for example in connection with supervisory and tax obligations, also require or entail data processing, for example archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. This also includes receiving and processing complaints and other reports, monitoring communications, conducting internal investigations or disclosing documents to an authority if we have sufficient reasons to do so or are legally obliged to do so. We may also process your personal data in relation to external investigations, for example by a law enforcement or supervisory authority or by a mandated private entity. Furthermore, we process data in order to serve our shareholders and other investors and to fulfill our obligations in this regard. For all these purposes, we process in particular master data, contract data and communication data, but also, under certain circumstances, behavioral data and data from the category of «other data». The legal obligations may arise under [Swiss law/Austrian law or EU law] but also under foreign regulations to which we are subject, as well as self-regulations, industry standards, our own «corporate governance» and instructions and requests from authorities.
We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.
For these purposes, we process in particular master data, contract data, registration data and technical data, but also behavioral and communication data. For example, as part of our financial management, we need to monitor our accounts receivable and accounts payable, and we need to avoid becoming victims of crime and abuse, which may require us to analyze data for relevant patterns of such activities. We may also conduct profiling and create and process profiles for these purposes and to protect you and us from criminal or abusive activity (see also Section 6). In the context of planning our resources and organizing our operations, we may need to evaluate and process data relating to the use of our services and other offerings or share information about them with others (for example outsourcing partners), which may also include your data. The same applies with respect to services provided to us by third parties. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the exchange and processing of data (including from you, for example as a customer or supplier or as a supplier representative).
We may process your data for further purposes, for example as part of our internal processes and administration or for quality assurance purposes and trainings.
These further purposes include, for example, training and educational purposes, administrative purposes (such as managing master data, accounting and data archiving, and testing, managing and continuously improving IT infrastructure), protecting our rights (for example to enforce claims in or out of court, and before authorities in Switzerland and abroad, or to defend ourselves against claims, for example by preserving evidence, conducting legal assessments and participating in court or administrative proceedings) and evaluating and improving internal processes. We may use recordings of (video) conferences for quality assurance purposes and trainings. These further purposes also include safeguarding other legitimate interests that cannot be named exhaustively.
Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for marketing mailings and for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. The legal basis for the processing of the data is, if you have given your consent, the DPA or, if and insofar as applicable, Article 6(1)(a) of the GDPR. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 12. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing (if and insofar as applicable Article (6)(1)(b) GDPR), in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.
Where we receive sensitive personal data (for example health data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims (if and insofar as applicable Article (6)(1)(f) GDPR). In some cases, other legal basis may apply, which we will communicate to you separately as necessary.
We may automatically evaluate personal aspects relating to you («profiling») based on your data (Section 3) for the purposes set out in Section 4, where we wish to determine preference data, but also in order to detect misuse and security risks, to perform statistical analysis or for operational planning. We may also create profiles for these purposes, i.e. we may combine behavioral and preference data, but also master data, contract data and technical data relating to you in order to better understand you as a person with your various interests and other characteristics. We may also create anonymous and – with your consent – personalized motion profiles of you.
If you are our customer, we may, for example, use «profiling» to determine which other products are likely to be of interest to you based on your purchases or receiving services. We may also use profiling to assess your creditworthiness before offering you to pay for a purchase by invoice. An automated data analysis may also determine, for your own protection, the likelihood of a particular transaction being fraudulent. This allows us to suspend the transaction for further clarification. «Profiles» are to be distinguished from «profiling». «Profiles» refers to the combining of different data in order to draw conclusions on essential aspects of your personality (for example what you like, how you behave in certain situations) from the totality of this data. Profiles may also be used for marketing, for example, or for security purposes.
In both cases, we pay attention to the proportionality and reliability of the results and take measures against misuse of these profiles or profiling. Where these can produce legal effects concerning you or similarly significantly affect you, we generally ensure human review.
In certain situations, it may be necessary for the efficiency and consistency of decision-making processes that we automate discretionary decisions that produce legal effects concerning you or similarly significantly affect you («automated individual decisions»). In these cases, we will inform you accordingly and take the measures required by applicable law.
An example for an automated individual decision is the automatic order acceptance by an online shop. Simple if-then decisions are not included (for example where a computer lets you access your user account after successfully checking your password), only discretionary decisions (for example the decision to enter into a contract). We will inform you in each case where an automated decision produces negative legal effects concerning you or similarly significantly affects you. If you do not agree with the result of such a decision, you will be able to communicate about it with a human being who will review the decision.
In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:
The group companies have access in particular to your master data, contract data and registration data, as well as behavioral and preference data in order to offer their own range of products and services to you or to advertise them. If you wish to object to the disclosure and use of data for marketing purposes, you can do so through us (Section 2), even if the processing concerns another group company once data has already been transferred. We also disclose your data to other group companies for certain products and services, for example if certain products and services originate from other group companies where we only coordinate the performance.
To be able to deliver our products and services efficiently and focus on our core competencies, we procure services from third parties in various areas. These include, for example, IT services, information transmission, marketing, sales, communication or printing services, services provided by dealers or service partners, facility management, security and cleaning, organizing and holding events and receptions, debt collection, credit agencies, address verification provider (for example to update address lists in case of relocations), fraud prevention measures and services from consulting companies, lawyers, banks, insurers and telecommunication companies. In each case, we disclose to these providers the data they require for their services, which may also concern you. These providers may also use such data for their own purposes, for example information about overdue claims and your payment history in case of credit information agencies or anonymized data to improve their services. In addition, we enter into contracts with these providers that include provisions to protect data, where such protection does not follow from the law. In some cases, our service providers may also process data on how their services are used and other data that is generated in the course of using their services as independent data controllers for their own legitimate interests (e.g., for statistical analysis or billing purposes). Service providers inform about their independent data processing activities in their own privacy statements.
If you act as an employee for a company with which we have concluded a contract, performance of this contract may require us to tell the company, for example, how you have used our service. Cooperation partners and advertising partners receive selected master data, contract data, behavioral data and preference data from us so that they can carry out non-personal analyses in their fields (for example about the number of our customers who have viewed their advertising) and, on the other hand, so that they can use data for advertising purposes (including targeting you). For example, advertising partners should be able to communicate with selected other customers of us and send advertising to them us.
Examples are criminal investigations, police measures (for example health protection concepts, the fight against violence, etc.), regulatory requirements and investigations, legal proceedings, reporting obligations and pre-court and out-of-court proceedings, as well as legal obligations to provide information and to cooperate. Data may also be disclosed if we wish to obtain information from public bodies, for example in order to justify a request for in information or because we need to say about whom we require information (for example from a register).
Other recipients include, for example, delivery recipients or third-party payees specified by you, other third parties in relation to agency relationships (for example if we share your data with your lawyer or your bank) or persons involved in administrative or legal proceedings. If we cooperate with the media and share materials with them (for example photos), this may also affect you depending on the circumstances. The same applies if we publish content (for example photos, interviews, quotes, etc.), for example on our website or in our other publications. As part of our business development, we may sell businesses, parts of businesses or companies to others or acquire them from others or enter into partnerships, which may also result in the disclosure of data (including from you, for example as a customer or supplier or as a supplier representative) to those persons involved in these transactions. In relation to communicating with competitors, industry organizations, associations and other bodies, data may be exchanged that also affects you.
All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).
We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if we are required to do so by law). Notwithstanding the foregoing, your data will continue to be subject to adequate data protection in Switzerland and the rest of Europe even after disclosure. For disclosure to other countries, the provisions of Section 8 apply. If you do not wish certain data to be disclosed, please let us know so that we can review if and to what extent we can accommodate your concern (Section 2).
In many cases, the disclosure of secret data is necessary in order to perform contracts or provide other services. Likewise, non-disclosure agreements generally do not exclude such disclosures of data nor disclosures to service providers. However, depending on the sensitivity of the data and on other circumstances, we ensure that these third parties handle the data appropriately. We cannot comply with your objection to the disclosure of data where the disclosure in question is necessary for our activities.
In addition, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example press photographers, providers of tools on our website, etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 12 for the website.
As explained in section 7, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in Switzerland as well as in the EU or the USA; in exceptional cases, in any country in the world.
If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.
Many countries outside of Switzerland or the EU or the EEA currently do not have laws that ensure an adequate level of data protection under the DPA or the GDPR. The contractual arrangements mentioned compensate for this weaker or missing legal protection to some extent. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in an individual case, and we take further measures (for example pseudonymization or anonymization) to minimize them.
Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.
We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 12. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with it (for example in case of backups or document management systems).
We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.
Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. We protect your data that is sent through our website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures. However, security risks can never be excluded completely; residual risks are unavoidable.
Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing.
To help you control the processing of your personal data, you have the following rights in relation to our data processing, under the DPA or, if and insofar as applicable, the GDPR:
If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).
You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section7 and additional information in Section 12.
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.
In particular, we may need to continue to process and keep your personal data in order to perform a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).
If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country.
You can find a list of authorities in the EEA here:
https://edpb.europa.eu/about-edpb/board/members_en.
You can reach the Swiss supervisory authority here:
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html
In Liechtenstein, the following data protection authority is responsible:
We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.
In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with registration data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called «cookie»).
Cookies are individual codes (for example a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website, and that your system (browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognized even if your identity is unknown.
Other technologies may be used to recognize you with some likelihood (i.e. distinguish you from other users), such as «fingerprinting». Fingerprinting combines your IP address, the browser you use, screen resolution, language settings and other information that your system tells each server), resulting in a more or less unique fingerprint. This makes it possible to go without cookies.
Whenever you access a server (for example when you use a website or an app, or because an e-mail includes a visible or invisible image), your visits can therefore be «tracked». If we integrate offers from an advertising partners or a provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in a particular case.
We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.
We distinguish the following categories of «cookies» (including other technologies such as fingerprinting):
In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage. For example, we may transmit the e-mail addresses of our users, customers and other persons to whom we wish to display advertisements to operators of advertising platforms (for example social media). If these persons are registered with them with the same e-mail address (which the advertising platforms determine by a matching process), the providers display our advertisements specifically to these persons. The providers do not receive personal e-mail addresses of persons who are not already known to them. In case of known e-mail addresses, however, they learn that these persons are in contact with us and the content they have accessed.
We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), these providers can determine that you are using our website. If you have an account with that social media provider, it can assign this information to you and thereby track your use of online offers. These social media providers process this data as separate controllers.
We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):
Click here to view the Google Analytics privacy policy.
Click here to view Cookiefirst’s privacy policy.
We currently use offers from the following service providers and social media platforms (insofar as they use data from you or cookies set on you for advertising control):
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The responsible body for the operation of the platform for users from Europe is Facebook Ireland Ltd, Dublin, Ireland. Their privacy policy is available at www.facebook.com/policy. Some of your data will be transferred to the USA. Objection regarding advertising is possible here: www.facebook.com/settings?tab=ads.
The following Facebook functions may be integrated on our website:
– Facebook Like button (allows the user to tell Facebook that they like something).
– Facebook Connect (allows the user to log in to their Facebook account and interact with our websites through that account).
– Facebook Share (allows the user to share an item on Facebook).
– Facebook Social Graph (allows our websites to pull elements from Facebook to our websites, e.g. profile pictures, public Facebook posts).
In relation to the data collected and processed when visiting our site for the creation of “Page Insights”, we share responsibility with Facebook Ireland Ltd, Dublin, Ireland. As part of Page Insights, statistics are collected about what visitors do on our site (comment on posts, share content, etc.). This is described at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our site is being used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on www.facebook.com/legal/terms/page_controller_addendum.
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Functions of the Instagram service are integrated on our pages. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
If you are logged into your Instagram account, you can link the content of our pages to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit to our pages with your user account. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Instagram.
For more information, please see the Privacy Notice of Instagram: https://instagram.com/about/legal/privacy/.
We use the functions of Instagram to make our offer accessible to a wider audience. Therein lie our legitimate interests, which serve as the legal basis for data processing.
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The following functions of the YouTube page operated by Google may be integrated on our website:
– YouTube video player (allows YouTube videos to be displayed on our websites).
– YouTube account login (allows users to log in to their YouTube account and interact with the Distributed Engagement Channel (DEC) through that account).
The controller of personal data is Google LLC / YouTube LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, or if you are habitually resident in the European Union (EU), the European Economic Area (EEA) or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google is certified under the Swiss-US and EU-US Privacy Shield Agreements, https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
YouTube’s privacy policy can be found here: https://policies.google.com/privacy.
YouTube plugins are used for the purpose of visually appealing presentation of our offers. Our legitimate interests in the placement of our offers therefore serve as the legal basis.
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The controller of personal data is, LinkedIn Corporation, 2029 Stierlin Ct, Mountain View, CA 94043, USA, or if you are habitually resident in the European Union (EU), the European Economic Area (EEA) or Switzerland, LinkedIn Ireland, Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
LinkedIn is certified under the Swiss-US and EU-US Privacy Shield Agreements, https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
LinkedIn’s privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy.
We use the components of LinkedIn to make our offer accessible to a wider audience. Therein lie our legitimate interests, which serve as the legal basis for data processing
We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.
We receive data about you when you communicate with us through online presences or view our content on the corresponding platforms, visit our online presences or are active on them (for example publish content, submit comments). These platforms also collect technical data, registration data, communication data, behavioral data and preference data from you or about you, among other things (see Section3 about these terms). These platforms usually perform statistical analysis of the way you interact with us, how you use our online presences and our content or other parts of the platform (what you view, comment on, «like», forward, etc.) and combine this data with other information about you (for example information about your age and your gender and other demographic information). In that way, they create profiles about you and statistics on the use of our online presences. They use this data and profiles to display to you our or other advertisements and other personalized content on the platform and to manage the behavior of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can control the analysis that these platforms generate regarding the use of our online presence to some extent.
We process this data for the purposes set out in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 12) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).
For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the platforms specified in Section 12.
This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.
Last updated: 25.04.2023
(zusammen “Social Media Partner”)
Die Social Media Partner nutzen meine oben genannten personenbezogenen Daten, um Dritte Personen zu ermitteln, die mir statistisch ähnlich sind (sog. “Statistische Zwillinge”). Dazu nutzen die Social Media Partner auch solche personenbezogene Daten von mir, die ihnen ggf. bereits vorliegen und die nicht von Aiways an den jeweiligen Social Media Partner übermittelt wurden (z.B. Name, Alter). Die auf diesem Wege ermittelten Statistischen Zwillinge erhalten dann Werbung über Aiways Produkte.
Die jeweiligen Social Media Partner gleichen meine oben genannten personenbezogenen Daten mit ihren Datenbanken ab, um zu überprüfen, ob ich beim jeweiligen Social Media Partner als Nutzer registriert bin. Ergibt der Abgleich, dass ich als Nutzer registriert bin, wird mir von diesem Social Media Partner keine oder weniger Aiways Werbung angezeigt.
Combined electricity consumption1 in kWh/100 km: 13.8 (NEDC); 17.0–16.6 (WLTP)
Combined CO2 emissions1: 0 g/km
Efficiency class: A+
¹The stated figures have been calculated using the legally required measurement techniques. Previously, consumption figures were measured using the New European Driving Cycle (NEDC). Since 1 September 2017, certain new vehicles have been given type approval in accordance with the Worldwide Harmonised Light Vehicles Test Procedure, WLTP). Compared with NEDC, WLTP represents a more realistic procedure for measuring electricity consumption. As of 1 September 2018, NEDC is gradually being replaced by WLTP. The electricity consumption figures measured using WLTP are, in many cases, higher than those measured using NEDC, which is attributable to the more realistic test conditions associated with WLTP.
We are currently legally obliged to state the NEDC figures. In respect of new vehicles that have already been granted type approval in accordance with WLTP, the NEDC figures are derived from the WLTP figures. Until it becomes mandatory, the statement of the WLTP figures is made voluntarily. NECD values, which are given as a range, do not form part of the offer, as they do not relate to a specific vehicle. They serve solely to facilitate comparison between different vehicle types. Aerodynamics, weight and rolling resistance may change due to optional extras and accessories and have the ability – just like personal driving style and weather/traffic conditions – to influence the electricity consumption and on-road performance of a vehicle. In terms of electric vehicles, in particular, higher or even significantly lower consumption figures may be recorded in real-life conditions.
For more information on the official electricity consumption of new passenger cars, please refer to the Guide on the Fuel Economy, CO2 Emissions and Power Consumption of New Passenger Car Models, which is available free of charge at all outlets, from DAT Deutsche Automobil Treuhand GmbH, Hellmuth-Hirth-Str. 1, 73760 Ostfildern, Germany, or at www.datgroup.com
