Dealer Privacy Policy

1. GENERAL PROVISIONS
   • This UAB „LM Auto“ legal entity code 302784123, address Ozo g. 10A, 08200 Vilnius (hereinafter referred to as “We” or “Bentley Vilnius”) Privacy Policy (hereinafter referred to as “ the Policy”) regulates the main purposes and terms of personal data processing and is supplemented by Bentley Motors Limited registered in England and Wales (legal entity code 0992897) Privacy Policy https://www.bentleymotors.com/en/pages/privacy- policy.html as far as it concerns Bentley Vilnius personal data processing.
   • We respect Your privacy and the right to Your personal data protection. We make every effort to ensure the security and confidentiality of Your Personal data and other information that is hosted on https://vilnius.bentleymotors.com/eu/en/home (hereinafter referred to as “the Website”).
   • Termes used in this Privacy Policy:
     • Personal data – any information relating to a natural person – a data subject who is or can be identified, directly or indirectly, in particular by reference to an identifier such as an identification number or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
     • Data subject (You) – natural person whose personal data are processed for the purposes and grounds specified in this Privacy Policy.
     • Other terms used in the Privacy Policy shall be interpreted according to the meanings provided in the Regulation of the European Parliament and of the Council (EU) No 2016/679 of 27 April 2016 (the General Data Protection Regulation) and other legal acts concerning the protection of personal data.

1. THE MAIN PRINCIPLES OF PERSONAL DATA PROTECTION

1. • The information we collect about You depends on what information You provide to us when You register for the products and (or) services offered on the Website, agree to use cookies and (or) subscribe to newsletters.
   • While using the Website, You are not required to provide us with any Personal data, but it may be that We will not be able to provide You with the services and (or) products offered on the Website.
   • We collect Personal data that You provide when You use the Website and register to purchase our offered products and (or) services:
     • The main information – name, surname, e-mail, telephone number, address;
     • Data relating to registration for the purchase of the services and (or) products offered on the Website - ordered service / product, car model, car state number, consent and disagreement on the processing of Personal data for the purposes of direct marketing (when You register for our newsletter) and related records;
     • Other data – data relating browsing of the Website (data collected using cookies and similar technologies).
   • We collect and process Your Personal data for the purposes and grounds specified in this Privacy Policy as specified bellow:
     • execution of the purchase of services and (or) products offered on the Website;
     • with Your consent, when Your Personal data is processed for the purpose of direct marketing when providing personalized offers;
     • We have the right to contact You without Your consent if you are our customer and We are offering You our goods and (or) services (or similar goods / services), supplying up-to-date information or asking for Your opinion on goods / services. In the latter case, You are given an easy-to-implement opportunity to disagree with the receipt of relevant messages.
   • You have the right to withdraw Your consent at any time, but the revocation of consent does not affect the legality of the consent-based data processing prior to the revocation.
   • We process Your personal data only to the extent that it is necessary to achieve relevant, clearly defined and legitimate purposes, taking into account Your privacy. In cases not covered by this Privacy Policy, Your personal data is processed only for the purpose of consent or contract.
   • We ensure that Personal data is processed accurately, fairly, and lawfully for the sole purpose of meeting purposes that precede the collection of Personal data, for the purpose of processing Personal data strictly in accordance with clear and transparent statutory processing of Personal data.
   • Your registration on the Website submitted under the provisions 2.3.1. and 2.3.2 (except your consent to the processing of Personal Data for direct marketing purposes) of this Privacy Policy shall be kept for a maximum of 3 (three) months when you provide Personal data for registration for a trial and for a maximum of 6 (six) months when You submit Personal data for registering for our services, counting from the moment your data is submitted to our Website.
   • We also inform You that records of telephone conversations with our Customer Service Centre staff are being made to ensure the quality of the services provided to You and to inform the Data subjects. Before recording a telephone conversation, the Data subject is informed about the recording and the purpose of the recording the conversation. Telephone conversation records are stored for 6 months and can only be listened if there are any suspicions about the violations of the provisions of this Privacy Policy, our and our customers' sales and (or) service agreements or our internal rules, the quality of our provided services, accidents or conflicts (incidents) with our customers or employees, in cases of material loss, damage or destruction.
   • We keep Your Personal data for no longer than the terms are provided in this Privacy policy, unless the law provides for a longer retention period for such Personal data.
   • Your Personal data is processed responsibly and safely. We, both in the process of processing Personal data Processing and in the course of Personal data processing, implement appropriate statutory data protection technical and organizational measures to protect Personal data processed from accidental or unlawful destruction, damage, alteration, loss, disclosure and any other illegal processing. Appropriate measures shall be determined taking into account the risks arising from the processing of Personal data.
   • We provide strict access control to Personal data processed and provide access to those our employees who need Personal data to perform their work duties and also, We monitor the use of access. We provide access to Personal data with passwords at the appropriate level and create confidentiality agreements with individuals who access Your Personal data.
   • Employees who have access to Personal data are instructed with the requirements of Personal data protection and must ensure the confidentiality of Personal data processed.
   • We note that when You register on the Website and then You sign the contract for the sale of products and (or) services, Your Personal data will be processed in accordance with the provisions of the concluded agreements.

III. THE CONDITIONS OF DIRECT MARKETING (THE NEWSLETTERS)

1. • If You agree to subscribe to our newsletter, We will use Your email address and phone number for individualized (automated solutions (profiling) information based on goods, services, discounts, offers, contests, events, news, surveys and other news. We will contact You by post, email, telephone or short message.
   • We will send You general information while sending general direct marketing proposals.
   • We can contact You without Your consent (mentioned in the provision 3.1. of this Privacy Policy) if our goods or services (or similar goods / services) are offered or We ask Your opinion about our goods / services. In the latter case, you are given an easy-to-implement opportunity to disagree on the receipt of relevant messages.
   • We may only provide Your email address to third parties providing specialized services only to send You a newsletter.
   • The retention period for Personal data (email address and telephone number) processed for the purposes of direct marketing is 3 years, but not longer than Your consent is valid. In the case of sending up-to-date information about goods or services (or similar goods / services) or asking for Your opinion about goods / services, the Personal data processed for the purposes of direct marketing are stored for as long as you are our customer or until you refuse to receive the mentioned information.
   • You can refuse our newsletters if You contact us by email info@bentley-vilnius.lt or by clicking on the link at the bottom of the newsletter.

1. THE DISCLOSURE OF YOUR PERSONAL DATA

1. • In order to ensure uninterrupted operation and proper service provision, We may disclose Your Personal data to our employees, managers, suppliers, subcontractors, service providers if reasonably required for the purposes stated in this Privacy Policy.
   • Your personal data may be disclosed on the basis of the performance of Bentley Motors contracts and (or) a legitimate interest, if reasonably required for the purposes stated in this Privacy Policy.
   • We may also transfer Your personal data to other third parties (processors) who process and (or) have access to Your Personal data and (or) access to such services, such as information systems, service providers and others who ensure the quality of services. In this case, we shall take appropriate measures to ensure that the processors who process Personal data perform only those actions We have been instructed to do so and ensure appropriate organizational and technical data security measures.
   • We have the right to disclose Personal data to public authorities for the proper implementation of legal requirements. In addition, Your Personal data may be disclosed to legal service providers where such personal data need to be disclosed in order to identify, implement or defend our rights and legitimate interests.

1. RIGHTS OF THE DATA SUBJECT

1. • As a data subject, you have the following rights:
     • to be informed about the processing of Your Personal data;
     • to obtain information about the sources of Your Personal data and what Personal data have been collected, for what purposes they are processed and to whom they have been provided;
     • to require rectification of Personal data processed if the data is inaccurate and / or incomplete;
     • to require the destruction of Your Personal data or the suspension of the processing of Your Personal data if the Personal data is excess or if You cancel the given consent or have other sufficient grounds;
     • in cases where Your Personal data is processed with Your consent or when processing is necessary for the execution of a contract with You, You have the right in a structured, commonly used and computer-readable format to receive Personal data related to Yourself that You have provided to us and to forward that data to another data controller, or to require to transfer such Personal data directly to another data controller when technically feasible (right to data portability);
     • You have the right to object to when Your Personal data is processed for the purposes of direct marketing.
   • We do not carry out such profiling of Personal data that may have legal consequences for You or may have a major impact on You, but sending individualized offers of direct marketing, for example, by personalizing the content of the letters according to Your needs and interests, You may be assigned to the appropriate category of customers. In this regard, You have the right to demand human intervention to express your views and to challenge the decision.
   • If you intend to exercise Your rights, You can contact the Company by email info@bentley-vilnius.lt. Please note that when implementing the rights, You must properly verify your identity. Therefore, if you intend to send a request to us, you must confirm Your identity by electronic means of communication that allow proper identification.
   • We will provide You with the requested information free of charge within one month, but if Your requests are manifestly unreasonable or disproportionate, in particular because of their repetitive content, We are entitled to charge a reasonable fee based on the administrative costs of providing the information or the messages or actions you request or We can refuse to act upon request.

1. YOUR DUTIES

1. • By using the services provided by the Website, You assume full responsibility for the correctness and accuracy of Personal data provided. By Providing personal data, You assume full responsibility for the lawfulness of Personal data provided and You are responsible for the loss of Bentley Vilnius and (or) third parties that may result from such Personal data processing.
   • In a case of change of Your Personal data or other related information, You must immediately and within 10 (ten) business days change and (or) supplement Personal data or other relevant information.

VII. THE RIGHTS OF BENTLEY VILNIUS

1. • Bentley Vilnius reserves the right to refuse access to the Website if you are under 16 years of age.
   • When we have doubts about the correctness of Personal data or other related information provided, we have the right to request the rectification and (or) supplementation of such data or other relevant information.
   • We have the right to send information notices about the changed services and (or) their terms and conditions and other information related to our activities and other information necessary to know.
   • We make every reasonable effort to ensure that the Website functions as smoothly as possible and that it continues to function, but we do not undertake to ensure the continued operation of the Website, if any factors beyond our control are affected.

VIII. FINAL PROVISIONS

1. • If you have any questions or complaints about the processing of Personal data, you can contact us by email info@bentley-vilnius.lt to the Data Protection Officer or you have the opportunity to register your call by calling +37052605000. Also, if You have any complaints, You can contact the State Data Protection Inspectorate, though first of all we will try to resolve all the situations with you.
   • This Privacy Policy shall be reviewed and updated at least once a year or upon changes in legislation concerning the processing of personal data.
   • Please note that the Website contains links to websites which belong to other companies. In this case, we recommend You to read the privacy statements of these websites and contact the managers of these websites directly if you have any questions about how they use Your Personal data.
   • We have the right to partially or fully amend the rules described in this Privacy Policy. We will notify You of changes by posting an updated Privacy Policy edition on the Website. For this reason, We recommend You periodically visit our Website, where You will always find the latest version of the Privacy Policy.