Information on the processing of personal data
Through this document, you will receive information about how your personal data is processed by wifi.se (Wifi.se Sweden AB SE556421121611) with headquarters Wifi.se – Box 24206, 104 51 Stockholm.
Your privacy is important to us and we therefore make every effort to protect your personal data in the best possible way. In this document, you will receive information about how we, as the data controller, process all personal data collected about you by us when you or the company you represent make a purchase, submit a vehicle for service or repair, when we purchase a vehicle from you or when you enter into a tire storage agreement, so-called tire hotel, on site with us. If you have any questions regarding our processing of your personal data or if you want to exercise any of your rights that we describe below, you are welcome to contact us at the contact details shown above.
Personal data that we process about you – Refers to dealers, workshops, tire hotels and other service companies in the car industry that are members of MRF. The personal data that we process is the data that you have provided to us or that we have collected from you or a third party.
Personal data that you have provided to us: When you as a customer enter into an agreement with us, you will provide certain information about yourself. The information you provide can be, for example, your name, the registration number of your vehicle, your social security number, your customer number, your car owner number, your contact and address details and your card number. We may also process other personal data about you that you provide to us as a customer.
Personal data we have collected from you or a third party: When you submit a vehicle to us for service or repair, we may collect registration numbers and information stored in the vehicle’s computer. It is information that is primarily of a technical nature such as e.g. fault codes and service history pertaining to your vehicle. We may also collect information about troubleshooting completed and what work has been done, including any products that have been repaired, replaced or installed.
When you enter into an agreement for the purchase of a vehicle or service with us, we may also collect information about your purchase, your service or repair, payment and information about the vehicle’s chassis number, or so-called VIN number.
We may also process your personal data that we gain access to through searches in the Swedish Transport Agency’s road traffic register, mainly contact details and registration numbers.
We may process the personal data stated above about you even if someone else submits your vehicle to us for repair or service on your behalf. If you hand in a vehicle that someone else is registered as the owner of or as a representative of a company, we process your name and contact details.
Purpose and legal basis for the processing of your personal data For the following purposes, we process your personal data to fulfill our agreement or take measures that you request before entering into an agreement:
• If you, as a customer or representative of a company, make a purchase, submit a vehicle for service or repair, if we buy a vehicle from you or enter into an agreement about tire hotel, we process your name, social security number, registration number or other identification number on the vehicle, your customer number, your car owner number, your contact and address details and your card number for the purpose of administering our customer relationship including your payment. We also process this information to fulfill our obligations arising from the agreements you have entered into with us and to provide you with the information about the products and services you have requested from us, e.g. to send service reminders under an ongoing service contract in the manner you have chosen, i.e. via SMS, email or postal delivery. Processing of information that is stored in the vehicle’s computer may need to be processed to perform service and maintenance or to be able to carry out troubleshooting and identify and remedy faults on the vehicle.
• If you request a quote from us, we process your name, your contact details and information about the quote during the quote’s validity period in order to be able to contact you to follow up on the quote and take measures at your request before a possible agreement is concluded.
• In order to handle any complaints or to be able to fulfill any warranty obligations arising from our agreement with you or the company you represent, we process your name, your contact details, the registration number or other identification number on the vehicle, information about your purchase and carried out troubleshooting and which work that has been performed, including information about any vehicles, parts or products that have been repaired, replaced or installed.
• In order to be able to establish your identity and request credit checks when one is required according to the agreement, we process information about your name and social security number as well as information about your financial situation. The processing of your social security number is clearly justified in view of the importance of secure identification.
• If you test drive a vehicle, we process your name, your contact details, driver’s license, social security number and information about the test drive so that, in accordance with our agreement with you, we can charge any fees or other costs that arose during the time you had the vehicle. We also process driver’s license information and your social security number in order to ensure your identity, check the driver’s license against the road traffic register and to know who has borrowed the vehicle and ensure that you have a driver’s license. The processing of your social security number is clearly justified in view of the importance of secure identification when lending our vehicles.
The information is a contractual requirement and if the information specified above is not provided to us, we will not be able to fulfill our agreement or fulfill our obligations in relation to you.
For certain purposes, we process your personal data with the support of a balancing of interests as a legal basis for the processing. In the balancing of interests, we have assessed that our legitimate interest in carrying out the processing outweighs your interest and your fundamental rights in not having your personal data processed. What is our legitimate interest is stated below. If you want to know more about how we have made this assessment, please contact us. You can find our contact details at the beginning of this privacy policy.
For the following purposes, we process your personal data based on a balancing of interests
• If you request a quote from us, we process your name, your contact details and information about the quote
in support of our legitimate interest in being able to facilitate you as a potential customer and to send you marketing. The purpose of the processing is to be able to contact you and follow up on the quote as well as send direct marketing via e-mail, SMS and postal mail so that you can receive an updated quote with the same information and options as when the quote was issued. This is because it is extensive work to produce a quote for a vehicle, with options, models and payment options.
• We process your name and contact details such as email, telephone number and address in order to communicate with you as a customer or customer representative by sending direct marketing and newsletters, service reminders and customer surveys via post, email or SMS. Our legitimate interest is to be able to communicate with you who have previously made a purchase or entered into a vehicle leasing agreement for marketing purposes.
• We process your name and contact details in order to communicate with you as a potential customer by sending direct marketing and newsletters via post, email or SMS. This applies on the condition that you provided your personal data voluntarily, e.g. in connection with a customer evening or similar, or that we have collected your contact details in your capacity as a representative of a company or organization. Our legitimate interest in processing your personal data is to be able to communicate with you as a potential customer for marketing purposes.
• If you submit the vehicle on behalf of someone else or enter into an agreement with us as a representative of a company, we may process information about your name, your contact and address information as well as information about the vehicle to the extent that it is necessary to fulfill our commitments in relation to our customer. Our legitimate interest in processing your personal data is to be able to communicate with you as a contact person and to follow up on who submitted the vehicle to us.
• We process data linked to your vehicle, e.g. details of completed troubleshooting and any work that has previously been carried out, including information on any parts or products that have been repaired, replaced or installed in order to perform safe repair and service services on the vehicle. The processing of such data is done for security reasons so that the correct repair and/or service can be carried out on the vehicle. We process this information for our legitimate interest in being able to show that we meet the requirements of the respective vehicle manufacturers, to be able to see what previous measures have been carried out for safety reasons and to facilitate the owners of the vehicle during service.
In addition to the processing of your personal data stated above, we also carry out processing that is necessary to comply with the applicable law, regulation or authority decision. For example, we save information about your agreement with us and purchase history to the extent necessary to comply with applicable accounting and tax legislation.
Who can access your personal data? As a starting point, your personal data will only be processed by us. However, we will share your personal data with other actors. These actors are mainly general agents and vehicle manufacturers, the Swedish Transport Agency, insurance companies and finance companies.
We will also share your personal data with actors who process personal data on our behalf, so-called personal data assistants. For marketing purposes, we may share your contact details with advertising agencies and printers for e.g. printing and distribution of mailings. Before you are allowed to test drive a vehicle, we may check your driver’s license in the Swedish Transport Agency’s road traffic register in order to ensure that you as a driver have a valid driver’s license. Our IT suppliers and any other suppliers we engage may also gain access to all personal data that we process about you, however only to the extent necessary for the purpose of these fulfilling their obligations in relation to us. If we have checked and/or repaired deficiencies noted at the time of your vehicle’s inspection, we can directly certify that the deficiencies have been rectified directly to the Swedish Transport Agency’s road traffic register.
our personal data will also be disclosed to the following actors who are themselves responsible for the processing of your personal data:
• For payment or credit information, we may share information about your card number or social security number as well as information about your financial situation to payment intermediaries and credit companies.
• When purchasing a vehicle, we may register your information in the Swedish Transport Agency’s road traffic register in order to be able to carry out the change of ownership.
• In individual cases, we may disclose your contact details and certain information about your vehicle to the vehicle manufacturer or the general agent for the car brand you purchased. It is the vehicle manufacturer’s or general agent’s own responsibility to inform you of exactly which personal data the vehicle manufacturer or general agent processes about you as a data controller. It can be personal data originating from you as a customer, data from the vehicle or other information about the vehicle, e.g. vehicle registration number or chassis number.
• We may disclose your personal data to insurance companies when you buy a vehicle from us or hand in a vehicle for service or repair.
• We may disclose your personal data to a finance company when you lease a vehicle from us.
As a general rule, we and our partners only process your personal data within the EEA. In cases where personal data is processed outside the EEA, this is only done in accordance with current data protection legislation. If you would like more information about the transfer or if you would like a copy of the appropriate safeguards, please contact us.
In addition to what is stated above, our partners, e.g. leasing companies, finance companies, vehicle manufacturers, general agents and insurance companies collect your personal data directly from you for their own account. For such data, our partners are responsible for personal data and therefore have their own responsibility to inform you about the processing.
How long do we store your personal data? We never process your personal data for a longer period of time than is permitted according to the applicable law, regulation, practice or authority decision. Personal data that we process in order to fulfill our agreement with you is processed as a starting point during the time it is necessary for us to be able to administer the contractual relationship and fulfill our commitments in relation to you. In order to comply with mandatory law, because you have given your consent to it or because we have the right to do so according to a balancing of interests, we may, however, save your personal data for a longer period of time in accordance with below.
• For accounting purposes, in accordance with applicable accounting legislation, we save information required by such law about our agreement with you for seven years.
• In accordance with applicable law, we are entitled to store your contact details for direct marketing purposes for a period of time after your purchase or after our agreement has expired. Depending on what the agreement relates to, this time varies. o If you request a quote, we save your name, contact details and information about the quote in order to be able to contact you and follow up on the quote as well as send direct marketing via e-mail, SMS and postal mailings during the time the quote is valid and for a period thereafter in a total of a maximum of 3 months from registration of the personal data and issuance of the quote in order to make it easier for you and to be able to offer you an updated quote with the same information and options from issuance.
o If you have submitted your vehicle for repair or service, we save your contact details for 2 years from the time the service or repair was carried out. We consider ourselves to have a legitimate interest in saving your data during this time because you, as a customer, typically expect information from us as a workshop when it is time to service your vehicle again, which normally takes place 12-24 months after the last service.
o If you have entered into an agreement to purchase a new vehicle from us, we will save your contact details for 5 years and if you have purchased a used vehicle from us, we will save your contact details for 3 years from when the vehicle was delivered. We consider ourselves to have a legitimate interest in saving your data during this period, taking into account that a vehicle is a consumer product. We believe that our marketing becomes more relevant to you after a time when it is more likely that you may want to buy a new vehicle again. We may therefore store your contact details in order to send you direct marketing via post, e-mail or SMS for as long as we are entitled to do so according to current personal data legislation, marketing laws and practices.
o If you have provided personal data voluntarily, e.g. in connection with a customer evening or similar, we save your name and contact details for marketing purposes for a period of a maximum of 6 months from when the information was received from you.
o If your personal data has been collected from someone other than yourself and relates to contact information in your capacity as a representative of a company or organization, we save your contact information for marketing purposes for a maximum of 3 months from the date of collection.
• We save the personal data that you provide in connection with a test drive for 3 months to administer any fees or costs that arise during the time that you dispose of the vehicle. If there is damage to the vehicle during the test drive, we have the right to store your personal data during the time the case is handled, i.e. until the damage is regulated.
• In order to handle any complaints or warranty obligations, we save your name, your contact details, the registration number of your vehicle, information about your purchase, completed troubleshooting and what work has been carried out as well as what parts or products have been repaired, replaced or installed during three years from the day the vehicle was delivered, the repair or service was carried out and from the issue of the warranty. The personal data is saved for three years, taking into account that a vehicle is a durable product and we, in order to handle your statutory right to claim on the vehicle, repairs or service, will need to see what work has been carried out and what parts or products have been repaired, replaced or installed.
• We may save vehicle data relating to your vehicle, e.g. information about service events, during the time the vehicle is in operation. This information is only saved together with the vehicle’s registration number and/or chassis number and not together with your contact details. The data is saved during the time that the vehicle is in operation for our legitimate interest in being able to offer future owners of the vehicle information about service and maintenance work that has been carried out on the vehicle and to be able to follow the vehicle’s history. This means that the data remains even if the vehicle changes owners.
Your personal data may be saved longer than stated above to the extent that we are obliged to do so according to law, regulation or authority decision.
Sensitive personal data We do not have the right to process sensitive personal data or information about crimes within the framework of our customer administration. In cases where we may need to process sensitive personal data, it is in cases where information about your health is processed because you have ordered a specially adapted vehicle, e.g. a car that is adapted for the disabled. In such cases, we obtain your express consent to the processing. We may also process sensitive personal data if it is necessary for us to be able to defend legal claims.
Your rights According to the data protection regulation, you have several rights regarding the processing of your personal data.
Revoking a given consent Consent only needs to be obtained if we cannot support our processing of personal data on any other legal basis. If you have given consent for any treatment, e.g. because we want to carry out processing that goes beyond the agreement or what is included in a balancing of interests, you have the right to withdraw all or part of a given consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before this withdrawal.
Right to access You have the right to receive confirmation as to whether personal data concerning you is being processed and to have access to information about how the personal data is processed, e.g. the purposes of the processing and which categories of personal data the processing applies to. You also have the right to receive a copy of the personal data that is being processed.
Right to rectification You have the right to have incorrect personal data corrected without undue delay, and, taking into account the purpose of the processing, to supplement incomplete personal data, i.a. by providing supplementary information.
Right to erasure (The right to be forgotten) Under certain conditions, you have the right to request the erasure of your personal data from us. Such conditions exist if the personal data is no longer necessary for the purposes for which it was collected or processed, if you withdraw your consent on which the processing is based and there is no other legal basis for the processing, if you object to the processing and there is no legitimate reason to continue with the processing that weighs more heavily, when the personal data has been processed in an illegal manner or if the personal data must be deleted to fulfill a legal obligation to which we are subject.
You do not always have the right to be deleted. If we e.g. needs your personal data to be able to complete an agreement with you or to administer a complaint case, the data does not need to be deleted. We may also process data linked to the vehicle, e.g. details of completed troubleshooting and any work that has previously been carried out, including information on any parts or products that have been repaired, replaced or installed in order to perform safe repair and service services on the vehicle during the time that the vehicle is in operation, linked to the respective vehicle registration number and/or chassis number.
Right to restriction of processing Under certain conditions, you have the right to request that the processing of your personal data be restricted. Such conditions exist if you dispute the correctness of the data (but only for a period of time that gives us the opportunity to check this), if the processing is illegal and you object to the deletion of the personal data and instead request a limitation of the use of the data, if you need the personal data to assert or defend legal claims despite the fact that we no longer need the personal data for the purpose of the processing or if you have objected to the processing pending verification of whether our legitimate reasons for processing your personal data outweigh your reasons.
The personal data does not need to be restricted if all the data we process is correct and necessary to fulfill an agreement entered into with you.
Right to object to processing You have the right to object at any time to the processing of your personal data based on a balancing of interests. We may no longer process personal data unless we can demonstrate compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms or if it is for the establishment, exercise or defense of legal claims. You also have the right to object to your personal data being processed for marketing purposes. If you object to marketing, your personal data will no longer be processed for such purposes.
You cannot object to such processing which is necessary for us to be able to fulfill an agreement entered into with you.
Right to file a complaint You have the right to file a complaint with the Swedish supervisory authority Datainspektionen or another competent supervisory authority that supervises the processing of personal data. You have the right to file a complaint with a regulatory authority in the country where you are domiciled, where you work or where the alleged infringement was committed.
Right to data portability You also have the right, under certain conditions, to obtain the personal data concerning you that you have provided to us in a structured, generally used and machine-readable format and have the right to transfer these to another personal data controller (data portability). The right to data portability exists when the processing is based on consent or on an agreement and the processing is automated. You have the right to transfer the personal data directly from the member company to another personal data controller when this is technically possible. Page 8 (8).
Contact Us
If you want to exercise your rights as above or otherwise want to get in touch with us for a reason
of our processing of your personal data, you can do so by contacting us by post, e-mail or telephone.
You can find our contact details at www.wifi.se
Form to apply for register extract is provided by us upon request.
Validity
This information on the processing of personal data was established on 2023-05-21.
wifi.se (Wifi.se Sweden AB)
