Privacy statement

VWE Remarketing B.V. – Privacy Policy

INTRODUCTION
1.1 VWE Remarketing B.V. (hereinafter referred to as “VWE”) supports the automotive sector in Europe with an online auction platform called Automotive Trade Center. VWE is located at W.M Dudokweg 37, 1703 DA, Heerhugowaard, registered with the Chamber of Commerce under number: 57217408.
1.2 For privacy-related questions, VWE can be reached at the above address, as well as via email at: privacy@vwe.nl.
1.3 Your privacy is important to us. This general privacy policy is intended to inform you about the processing of personal data by VWE under the General Data Protection Regulation (“GDPR”). Depending on the circumstances, VWE may act as the data controller or as a data processor in the processing of your personal data.
1.4 Are you a VWE customer? For more detailed information about the processing of personal data by VWE as a data controller, please read the comprehensive privacy policy for VWE customers.

CATEGORIES OF PERSONAL DATA
2.1 VWE processes the following categories of data, which may include personal data:
2.1.1 First and last names;
2.1.2 Year of birth;
2.1.3 Gender;
2.1.4 License plate numbers;
2.1.5 Company names;
2.1.6 Chamber of Commerce (KVK) numbers;
2.1.7 Bank details;
2.1.8 Postal codes;
2.1.9 Telephone numbers;
2.1.10 Email addresses;
2.1.11 Traffic data and user data related to the use of VWE’s websites, apps, and online platforms;
2.1.12 RDW data from VWE customers;
2.1.13 Customer numbers of VWE customers;
2.1.14 Membership numbers of garage networks from VWE customers;
2.1.15 Membership numbers of garage software packages from VWE customers;
2.1.16 Membership numbers of industry organizations from VWE customers;
2.1.17 License plate numbers of vehicles;
2.1.18 Data on the condition of vehicles;
2.1.19 Other publicly available data on vehicles;
2.1.20 Other data held by the Dutch Road Traffic Authority (RDW) that is public for general purposes, insofar as VWE has access to it as an information provider for the vehicle industry, within the limitations of applicable laws and regulations;
2.1.21 Other personal data provided by you to VWE.

PURPOSES OF PROCESSING PERSONAL DATA
3.1 We process contact information to stay in touch with you, for example, in response to inquiries and to fulfill and maintain our agreements with you.
3.2 VWE acts as a processor for data controllers in the vehicle industry. VWE is a recognized information provider by the RDW. Information providers are organizations that facilitate communication between the RDW and individual companies (authorized holders) in the transport sector and designated organizations that receive and process data into information products. For more information about this processing of personal data, consult the privacy policy of the data controller or contact them directly. You can also refer to the RDW’s privacy policy or contact them if you have any questions.
3.3 If you have subscribed, we use your email address to send you updates such as news, developments, and new features. We request your consent for sending the newsletter.
3.4 When VWE acts as a processor, the legal basis for processing your personal data is determined by the circumstances between you and VWE’s customer. This may be necessary for the performance of a contract with you or due to the legitimate interest of VWE’s customer to process your personal data. You have the right to object to the processing in your specific situation if legitimate interest is the basis for processing your personal data.

OUR WEBSITES, APPS, PLATFORMS, AND COOKIES
4.1 On our websites, we use technologies that can read information from or store information on your device (hereinafter: “cookies”). Cookies allow us to track statistics on the number of visitors and which pages are most viewed.
4.2 To track statistics, we use a cookie from Google as part of the “Analytics” service. This includes statistical information such as the number of visitors, the most visited pages, and the duration of the visit. The information is stored by Google on servers in the EU/EEA or the United States. Google is certified under the EU-US Data Privacy Framework. We choose the most privacy-friendly settings in Google Analytics whenever possible.
4.3 We may also share this usage behavior with advertising networks. This behavior is combined by advertising networks with similar information obtained from your visits to other websites where they advertise. Based on this, an interest profile is created to show you relevant ads on other websites, tailored to this interest profile.
4.4 You can delete placed cookies via your browser and disable the acceptance of (certain) new cookies. Consult the following hyperlinks for more information on how this can be set in different internet browsers: Chrome, Microsoft Edge, Firefox, Safari.
4.5 For more information about our websites, apps, platforms, and cookies, please refer to our detailed privacy policy.
RETENTION PERIODS
5.1 As a data controller, VWE does not retain personal data longer than necessary for the purposes for which they were processed. VWE retains personal data longer to the extent necessary to comply with a legal obligation, such as tax retention periods.
5.2 When VWE acts as a processor, the retention period is determined by the data controller, who is usually VWE’s customer.
5.3 The RDW determines the retention period for personal data that it holds and to which VWE has limited access, subject to applicable laws and regulations. You can refer to the RDW’s privacy policy or contact them if you have any questions.

CATEGORIES OF RECIPIENTS
6.1 VWE uses external service providers to host your personal data and perform the processing mentioned in article 4 “Cookies”. These service providers may receive and process your personal data to the extent necessary to perform their tasks on our behalf.
6.2 When VWE acts as a processor, VWE’s customer may receive your data from us. This may also include personal data from the RDW source. VWE only provides license plates and vehicle information from the RDW source. The legal basis is usually that this information is necessary for our customers’ services in the transport sector, such as garage owners. VWE does not provide your name, address, or other sensitive data from the RDW source. VWE also does not have access to those categories of data at the RDW.

YOUR RIGHTS
7.1 If VWE is the data controller, you have the right to request VWE for access to, correction, supplementation, deletion, or restriction of your personal data, or to object to the processing. Additionally, in certain circumstances, you have the right to data portability. Direct your request, providing as much detailed information as possible, to: privacy@vwe.nl.
7.2 You have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
7.3 You are not legally required to provide your personal data. Failing to provide personal data may result in certain services not being (optimally) provided to you.
7.4 You have the right to withdraw your consent for the processing of personal data at any time. This does not affect the lawfulness of the processing that took place based on your consent before withdrawal. Withdrawing your consent may result in certain services no longer being provided to you.
7.5 When VWE acts as a processor and you contact VWE instead of the data controller, we may refer you to our customer.

CHANGES
8.1 This privacy policy may be amended. We will publish the most recent version of this policy on our website.