Privacy Policy for Suzuki Connect Europe Helpdesk

The data controller

Magyar Suzuki Corporation Ltd. is the data controller (seat: H-2500 Esztergom Schweidel J. u. 52; e-mail: privacy-contact-eu@suzuki.hu, hereinafter referred to as "SUZUKI" or "we", „us”, „our”)

urpose of the data processing

The purpose of the processing is to provide customer service to our customers in connection with the Service in order to respond to your enquiries and deal with your requests, demands or complaints, and to provide you with access to customer service and to identify you as our customer in this context. In cases where it is necessary to investigate complaints or claims of a technical or IT nature, your vehicle details will be transferred to Suzuki's parent company, Suzuki Motor Corporation, or other service providers of Suzuki Motor Corporation, to assist us in responding to and properly resolving complaints and claims.

Scope of personal data processed

We process the following personal data about you for the purposes set out in this Privacy Notice in order to provide customer service and related services:

• Personal identification data: name, such as surname, first name, which you provide to us for customer service purposes;
• Contact details: country of residence, e-mail address that you provide to us for customer service purposes;
• Vehicle details: vehicle chassis number;

·         Subscription details: contract ID;

• Description of the subject of the enquiry or complaint and any related attachments that you provide to us for customer service purposes.

The processing of this data is necessary to identify you, contact you and provide you with services through our customer service. The provision of this information is voluntary, but without it we will not be able to provide you with customer service or deal with your complaints or requests.  

Personal data or any other data that you provide to us but that we are not authorized to process (e.g. data not necessary for customer service) will be deleted as appropriate. In such a case, we may not be able to provide you with our services through customer support or deal with your complaints or requests, but we will notify you of this fact.

In all cases, the data processed will be treated in accordance with the principles of need-to-know and data minimization.

egal bases for data processing

By responding to your questions or requests, processing your claims and complaints, the processing is necessary for the performance of the contract between you and SUZUKI pursuant to Article 6(1)(b) of the GDPR ("Contractual Legal Basis").

The processing is necessary for SUZUKI's legitimate interests pursuant to Article 6(1)(f) of the GDPR ("Legitimate Interest Legal Basis") in relation to bringing, asserting or defending legal claims.

For the following purposes, we process the following categories of personal data on the following legal bases:

Legitimate interest and balancing of interests

SUZUKI has carried out a balancing of interests test prior to processing where SUZUKI relies on a legitimate interest in the processing of personal data. In performing the balancing of interests, SUZUKI took into account its internal organizational structure, internal operating rules and requirements, the nature and purpose of the services provided in relation to customer support, the scope, nature and type of personal data processed in the course of providing the services, the expected amount of data and the expected number of data subjects, as well as the impact of the envisaged processing on the rights and freedoms of data subjects.

On the basis of the balancing of interests tests carried out, SUZUKI is of the opinion that the envisaged processing will not disproportionately infringe your rights and freedoms and SUZUKI will therefore rely on its legitimate interests in the processing.

If you have any questions about the balance of interest test we have carried out, please contact us at privacy-contact-eu@suzuki.hu.

Data retention period

Your customer service enquiry will be kept for 160 days after your enquiry is closed.

If your request includes a complaint, we will keep a copy of the complaint and the record of the complaint and a copy of our response to the complaint for three years, in accordance with Article 17/A (7) of Act CLV of 1997 on Consumer Protection.

Personal data relating to any (civil) law claims will be kept until the end of the fifth year as the limitation period for (civil) law claims is set for five years in general. In the event that official or judicial proceedings are instituted in connection with our services, we may continue to process your personal data for the duration of such proceedings until their final conclusion.

Who has access to the personal data?

Your data will be accessible to specific employees of the Mobility Services Department and the Legal & Compliance Department within SUZUKI.  

In the event of a technical or IT-related complaint or fault report, if it is necessary for resolving and investigating the report, your vehicle data will be transferred to SUZUKI's parent company, Suzuki Motor Corporation (http://www.globalsuzuki.com/corporate/index.html), and other service providers of Suzuki Motor Corporation (IBM Group, Fujitsu, Lenovo).

SUZUKI uses third party IT systems or services to support its internal processes. For the purposes of the system or service and pursuant to an appropriate data processing agreement between SUZUKI and the service provider, personal data may be accessible to such service providers. Thus, personal data may be accessible to the following data processors:

·         Zendesk, Inc. (incorporated under the laws of State of Delaware and registered in the register under 4661237) for the technical servicing of the website.

·         Unbabel (incorporated under the laws of [*] and registered in the register under [*]) providing translating services.

What foreign data transfer safeguards do we apply?

We process your personal data in accordance with Hungarian and European data protection laws and transfer the data within the European Economic Area ("EEA") and to countries outside the EEA, including Suzuki's parent company Suzuki Motor Corporation in Japan. Where we need to transfer your data to a country outside the EEA, we will do so on the basis of an agreed adequacy decision by the European Commission or, for example, on the basis of a contractual obligation to ensure that a third party who has access to your personal data will provide you with a level of protection of your personal data at least equivalent to that which is afforded to you within the EEA. In the absence of these, we will in all cases put in place appropriate safeguards to maintain the security of your data.

One such safeguard is the application of the Standard Contractual Clauses, which have been adopted by the European Commission and which we have also put in place, and for which you can find more information at the link below:

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_hu

If you would like a description of the safeguards SUZUKI provides in relation to personal data transferred outside the EEA, or if you require further information about them, please contact us at privacy-contact-eu@suzuki.hu.

What are your rights?

You have the following rights in relation to our processing:

1.    Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You have the right to obtain one copy of the personal data undergoing processing. If you request additional copies, we may charge a reasonable fee based on administrative costs.

2.    Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

3.    Right to erasure (right to be forgotten): You have the right to ask us to erase your personal data, and we must comply if the legal requirements of such request are met.

4.    Right to restriction of processing: You have the right to request the restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5.    Right to data portability: You have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and the right to transmit that personal data to another entity without hindrance from us.

6.    Right to object: You have the right to object, on grounds relating to your particular situation, at any time, to the processing of your personal data by us and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

7.    You also have the right to lodge a complaint with the competent supervisory authority in the particular Member State of your habitual residence for alleged infringement of the GDPR. If you reside in Hungary, that is the Hungarian Data Protection and Freedom of Information Authority (address: 1055 Budapest, Falk Miksa utca 9-11., Telephone: +36-1-391-1400, Telefax: +36-1-391-1410, e-mail: ügyfelszolgalat@naih.hu)

You may exercise the rights set out in the above paragraphs by contacting us at privacy-contact-eu@suzuki.hu.

Please note that the aforementioned rights might be limited under the applicable national law.

Data Protection Officer

SUZUKI has appointed a Data Protection Officer who can be contacted at privacy@suzuki.hu