LAST UPDATE: 22 October 2020
This Policy describes the privacy practices of the Aixam-Mega family of brands and companies, such as Aixam, Minauto, Aixam-Pro, e-Aixam (collectively, “Aixam,” “we,” “our,” and “us”). We respect your privacy and value our relationship with you.
We may collect the following types of information:
We generally collect your information in three ways: (1) when you provide it to us; (2) when we collect it automatically; and (3) and when we receive it from other sources.
Information you provide to us. Some examples of when you provide us information include when you: submit information on our Sites; participate in an event, contest, other or promotion; purchase vehicles, products, or services in our retail stores; and communicate with us. Some examples of the types of information you provide us include: contact and identification information; demographic information; information about your vehicles and products; and audio, electronic, or visual information.
Information collected automatically. Some examples of information we collect automatically include:
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. If you set your browser to reject cookies, parts of the Sites may not work for you.
Pixel tags, web beacons, clear GIFs, or other similar technologies. These may be used in connection with some of our Sites, emails, or advertisements, to, for example, track the actions of Site users, compile statistics about Site usage and response rates, determine whether you have opened and acted upon our emails, and assess the effectiveness of our marketing.
http://www.adobe.com/privacy/marketing-cloud.html for more information about how Google and Adobe collect and use data when you use their partners’ websites or mobile applications.
We also use third-party advertising services to provide advertisements for Aixam vehicles, products, or services that may be of interest to you when you visit websites or other online services. We allow select third parties, including these analytics and advertising services, to place cookies on our Sites. These third parties may collect information about your online activities over time and across third-party websites, and they may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), and European Digital Advertising Alliance (eDAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.
Ermes and its subsidiaries are among the third parties that may deposit cookies on the site you visit. Cookies enable the display of targeted advertisements on the websites you visit (based on your online and offline consumption habits, shopping carts, etc.) by Ermes' advertiser clients or by Ermes in the context of marketing campaigns carried out on behalf of its advertiser clients. Ermes cookies are also used to create "qualified" profiles or segments based on various criteria defined by its advertiser clients (including gender, age, etc.), and to conduct marketing research, audience analysis and performance measurement in order to assess the quality of services and the performance of advertising campaigns. In order to offer these services to its advertiser clients, Ermes deposits its cookies on your terminal when you visit one of our partner websites. The data processed by Ermes may include: name, e-mail address, postal address, telephone number, IP address and your operating system or browser type. The data processed by Ermes is hashed in order to ensure the confidentiality and security of Internet users' data. For more information, Ermes encourages you to consult its charter regarding the protection of personal data, and reminds you that you may at any time oppose the deposit of Ermes cookies by clicking here: https://www.ermes.ai/politique-de-confidentialite/
Do Not Track requests. Some browsers may transmit “Do Not Track” (“DNT”) signals to the websites you visit. Because there is not common agreement about how to interpret DNT signals, we do not take action in response to them.
When you participate in one of our test drives, or an Aixam rental experience, the vehicle that you use may be equipped with other technology that may collect information related to the state of the vehicle, including, for example, the vehicle’s location, speed, and rate of braking or acceleration. Aixam may use this information to provide roadside assistance, to locate lost or stolen vehicles, and as otherwise described in this Policy.
Information we receive from other sources. We may combine the information that you provide us and that we collect automatically with information that we collect from other sources, such as our dealers, distributors, the business partners we work with to make certain products and services available to you (as described below), consumer data resellers, and other third-party sources.
For example, we receive information from our dealers, distributors, and business partners, such as contact and identification information; financial information; and information about vehicles, products, and website content or services that you have viewed, inquired about, or purchased. Our independent dealers, third-party distributors, and business partners are separate legal entities with their own privacy practices. For questions about the privacy practices of a dealer, distributor, or business partner you interact with, please contact them directly.
We may also obtain demographic and other information about you from consumer data resellers and other third-party sources. This information allows us to enhance our existing information for accuracy, security, and other purposes, such as increasing the relevance of our marketing, improving our communications with you, personalizing your experience with our Sites and services, and detecting fraud.
Some information we collect from third-party sources is publicly available. For example, we may collect information that you or others submit in a public forum, such as a blog, social network, or chat room.
We also create information ourselves when we analyze the information we have collected about you. And we combine information that we collect about you, as described above, with information that we collect in other contexts.
We may use the information we collect to:
We may also use your information for other internal Aixam business operations, as permitted by applicable law, and other uses consistent with the context in which the information was collected or with your consent.
We may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.
Communications. Communications with you in connection with these uses may be via different methods, such as mail, telephone, email, text message, social media, or other electronic messages, or via our Sites.
Information We May Share
We may share your information as follows:
We may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
Our Sites may contain links to external websites, mobile applications, or third-party services that are not operated by Aixam, and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the related websites, mobile applications, third-party services, or social media platforms (“Third-Party Sites”), nor any association with their operators, and we are not responsible for the privacy or other policies or practices of those Third-Party Sites. To learn about the information collected by Third-Party Sites, please visit their privacy policies.
We maintain technical and organizational security measures designed to help protect your personal information from unauthorized access, disclosure, alteration, or destruction. Unfortunately, no data transmission or storage system is 100% secure or error free, and we cannot guarantee the security of the information we collect.
We retain your personal information as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law.
To determine the period for which your personal information will be retained, Aixam considers criteria such as: (i) the nature of our relationship with you and the types of vehicles, products, or services we have provided to you, or you have requested; (ii) the sensitivity of the information and the purposes for which it was collected; (iii) the nature and timing of your interactions with us (including with our Sites, communications, etc.); (iv) any applicable legal or contractual requirements to retain information for a certain period of time, including any retention obligations related to actual or potential litigation or government investigations; and (v) the impact on the vehicles, products, and services we provide if the relevant information were deleted.
You have certain choices about the information you provide and how it is used and shared. For example, you can:
The controllers for personal data covered by this Policy are Polaris Sales Europe SARL, Place de l’Industrie 2 1180 Rolle – Switzerland.
The contact information for Aixam EU data protection officer is:
By mail: Polaris Sales Europe SARL, Place de l’Industrie 2 1180 Rolle – Switzerland,
Attention: EU Data Protection Officer
By email: email@example.com
Aixam’s Lawful Basis for Processing Your Personal Information
Our lawful basis for processing personal data covered by this Policy will depend on the purposes of the processing. To the extent we process personal data because it is necessary to perform a contract with you, our legal basis for that processing is that it is necessary for the performance of a contract with you.
When we are required to share personal data with law enforcement agencies or other governmental bodies, or we otherwise process personal data to comply with our legal obligations, we do so on the legal basis that we are under a legal obligation to do so.
We use consent as our basis for processing to the extent required by applicable law, or as we otherwise deem appropriate, for example, before we collect geolocation information from your mobile device.
We also process personal data on the lawful basis that it is necessary for Aixam’s legitimate business interests, which may include: providing, improving, developing, and promoting our vehicles, products, services, and Sites; communicating with and otherwise managing our relationship with you; enhancing the safety and security of our vehicles, products, services, Sites, employees, and others; and protecting Aixam and our business partners from wrongful conduct.
Your Individual Rights
In accordance with applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances, and may be limited by local law: (i) right of access, (ii) right to correction, (iii) right to erasure, (iv) right to restriction of processing, (v) right to data portability, (vi) right to object to certain types of processing, and (vii) right to withdraw consent to certain types of processing. Most of these rights are not absolute. You may exercise these rights by submitting a request to us using this request form. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. Please note that we may ask for additional information to verify your request before responding to it.
We will seek to address any complaints submitted to us using the contact information listed in the “Contacting Us” section below. In addition, you have the right to lodge a complaint with your local supervisory authority or regulator.
We may process your information in France and other locations around the world. Those countries may not have the same level of protection for your personal information as your country. By using our Sites or services or otherwise providing us your information, you acknowledge and understand that your information will be transferred to and processed in France and these other countries.
We do not intentionally collect information from children under the age of 13, or the relevant minimum age under applicable local law. The Sites are not directed to or intended to be used by children under the age of 13, and we request that children under the age of 13 not provide personal information through the Sites.
We may change this Policy. Please review the “Last Updated” legend at the top of this Policy to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. We encourage you to look for updates and changes to this Policy by checking this date when you access our Sites and services.
If you have any questions about this Policy, please contact us using the contact information below:
Polaris Sales Europe SARL
Place de l’Industrie 2
Attention: EU Data Protection Officer
By email: firstname.lastname@example.org
For all others, our contact information is:
56 route de Pugny
73101 Aix-les-Bains cedex
Attention: Legal Department
By email: email@example.com
By phone: 00 33 (0)479614245 (Monday to Friday, 8 am-12.15 pm/1.30 pm-6 pm CET)