CTC Autoleasing Ltd (hereinafter “we”, “us” or “our”), member of the Cyprus Trading Corporation Plc Group of Companies (the “Group”) operates the website www.autoleasing.com (hereinafter the “Website”) and is the controller of the information collected or provided via this Website.
1. What is personal data?
Personal data is information that may identify you directly or indirectly. Indirectly means in conjunction with other information, such as your name, postal address, email address and phone number, or a unique identification device number.
2. Information that this policy applies to
• This Website.
• E-mail, text and other communications between you and this Website.
• Mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
It does not apply to information collected by:
• Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries).
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
We will not disclose your information to third parties, except where it is part of providing a service to you. We will only otherwise disclose your information where we have your express permission or we are obliged by the law to do so.
3. Information that we collect and how
We collect and use several types of information from and about users of our Website, including information by which you may be personally identified and that is defined as personal data or personally identifiable information under applicable law (“Personal Information”), such as your first and last name, e-mail address or IP address.
Categories of Personal Information we collect and use on or through our Website include:
• Information that you provide by filling in forms or registering on our Website, in particular at the time of submitting your CV.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your search queries on our Website.
• When you access our Website from a mobile device like a tablet or phone, we receive information about your location (IP Address), your device, including one or more unique identifiers for your device.
• Data you provide when registering as a customer or as a member in our database.
• Data you provide when registering a person to receive notifications via e-mail or sms or other commercial communication.
We also collect information automatically, for example, by the use of “cookies”, as outlined below, and certain types of information when your web browser accesses the Website or when you access content on other websites, which is served by the Website.
4. Information collected through automatic data collection technologies
As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
• Details of your visits to our Website, including any form of aggregate data, navigational data, location data, click-stream data, or historical data, number of clicks and how you interact with links on the Website, domain names, landing pages, pages viewed, referral data (e.g. the URL of the last page you visited prior to clicking through to the Website and the address of the exit page when you left our Website), log files and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system and browser and platform type (e.g. a Firefox browser on a Macintosh platform) and language, access times, the content of any undeleted cookies that your browser previously accepted from us. We use this information to track how users are accessing and using our Website.
The information we collect automatically is statistical data and includes Personal Information, or we maintain it or associate it with Personal Information we collect in other ways or receive from third parties. The above information helps us to improve our Website and to deliver a better and more personalized service, including enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.
5. Processing of Sensitive Data
In some cases, we may process specific categories of personal data about you (“sensitive data”). For example, we may process sensitive data that you have made public. We may also process sensitive data, as the case may be, to support, exercise or defend legal claims. We may also process your sensitive data if you have freely given your prior express and separate consent, in a specific context for a specific purpose.
6. Your consent
We may share your Personal Information with our agents, e-commerce partners and contractors or other service providers, as this may be needed to carry out the performance and functionality of the Website.
7. Management of Curriculum Vitae
By submitting your CV through our Website or via any other means, your personal data is being processed by the companies of the Group for employment evaluation purposes only.
We provide you with the option to choose, should you wish to do so, to keep your CV for an additional period of time after the completion of the hiring process for the particular vacancy you have applied for, or for consideration for future potential vacancies, by filling in your details in the online form of our Website and clicking on the available tick-box, available for that purpose. If you do not do this, your CV will be deleted immediately after the vacancy is filled. Additionally, you have the right to retract your consent, as noted below.
Within the same framework, we process all other data you may provide to us or that we may obtain during the evaluation process, such as psychometric tests, which, if the necessary consent is not given, are also deleted immediately after the filling of the specific vacancy along with your other data.
8. Information Security
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures dictate that we may occasionally request proof of identity before we disclose personal information to you.
No method of collection, storage or disclosure is 100% secure, so we cannot guarantee its absolute security.
If you have submitted a CV through our Website, we may contact you to update on the status of your application or other vacancies.
When you communicate with us (via email, phone, through the Site or otherwise), we may maintain a record of your communication (including call recordings).
A cookie is a small information file that is sent to your computer, mobile or other device when you visit a website and it will recognise your device on future visits. These types of files do a number of different jobs such as remembering your preferences and chosen items, assisting you to improve your site experience as well as trying to ensure that the adverts or offers you see online are more relevant to you. Cookies are used on the Website in order to offer our users a more customized browsing experience and can be divided into 4 types, as outlined below.
Category 1: Strictly necessary cookies
These cookies are essential in order to enable the site to provide services you have asked for, such as remembering your shopping bag items.
Category 2: Performance cookies
This type collects anonymous information on how people use the site and the data is merged with other users to enable us to improve how the site operates. For example we utilise Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never show personal details from which your individual identity can be established.
Category 3: Functionality cookies
These remember choices you make such as language. They can then be used to provide you with an experience more appropriate with your selections and make your visits more tailored and pleasant. The information is also merged with other users on an anonymous basis to enable us to improve how the site operates.
Category 4: Targeting cookies or advertising cookies
These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They remember the websites you have visited and that information is shared with other parties such as advertisers.
You can change the settings on your browser to prevent cookies being stored on your computer or mobile device without your explicit consent. Your browser “help” section will normally provide details on how to manage the cookie settings.
11. Site statistics
We may disclose aggregate, anonymised statistics about the number of visitors to the Website. We use an independent measurement and research company to gather data regarding the visitors to the Website on our behalf using cookies and code which is embedded in the site. Both the cookies and the embedded code provide statistical information about visits to pages on the Website, the duration of individual page view, paths taken by visitors through the site, data on visitors’ screen settings and other general information. We use and store this type of information, as with that obtained from other cookies used on the site, to improve the services to users.
12. Retention of Personal Information
To the extent we have collected your Personal Data for purposes of provision of services, customer management, and customization of content (for descriptions of these purposes see above), we keep your Personal Information for as long as you have an account with the Website, and as needed to provide you with our respective services.
Personal Information used for analytics purposes will be stored as long as necessary to analyze the usage of our Website and services, usually for a period of 26 months.
The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depends on the nature of our legal obligations and claims in the individual case.
To learn more about the expiry date of cookies, see above section.
13. Legal bases for collection, use and disclosure of your Personal Information
There are different legal bases that we rely on to collect, use and disclose your Personal Information, namely:
• Compliance with legal obligation: We are permitted to use your Personal Information to the extent that this is required to comply with a legal obligation to which we are subject.
• Performance of Contract: We to use your Personal Information where this is necessary for the performance of a contract you are a party to or at your request prior to the entering into a contract.
14. How we protect the security of your Personal Information
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
15. Disclosures of your Personal Information
We may disclose your Personal Information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect our rights, property, or safety, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
16. Third party sites
Our site may contain links to and from the websites of our partner networks, advertisers and other third parties. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
17. Third party cookies
Our site may contain third party cookies, which are cookies associated with a file requested from a different domain.
These are owned and operated by a party other than us. We have no access and cannot control third party cookies. The third party organisations that place cookies have their own privacy policies, so it’s worth checking the third-party website for more information about their cookies and how to manage them.
18. Managing cookies
Most browsers allow you to turn off cookies. To do this, look for the “help” menu on your browser, which on most browsers will tell you how to prevent it from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
Switching off cookies may affect the way in which the site operates (e.g. switching off cookies will not allow you to save and retrieve your shopping cart at next login) or restrict your use of the site.
19. Your rights related to your Personal Information
Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose and that is related to you, including the right to:
• Receive information on the Personal Information we hold about you and how such Personal Information is used (right to access).
• Rectify inaccurate Personal Information concerning you (right to data rectification).
• Delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”).
• Receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability).
• Object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object).
• Restrict, in some cases, our use of your Personal Information (right to restriction of processing).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website and our services.
You may, at any time, send us an e-mail at email@example.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Please note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
20. Personal Data Retention
In general, we will delete the personal data we collect from you if it is no longer necessary to achieve the purposes for which it was originally collected. However, we may be asked to retain your personal data for a longer period of time due to legal provisions.
In addition, we will not delete all your personal data if you have asked us not to contact you in the future. To this end, the Company maintains files that contain information about individuals who do not wish to be contacted in the future (eg via group email). We categorize your requests as consent for the storage of your personal data for the purposes of maintaining this file unless you give us different instructions.
21. Transfer of Business
23. Contacting us
CTC Autoleasing Ltd is the data controller for the purpose of the Processing of Personal Data under the General Data Protection Regulation (GDPR).
You have the right to access the information which we hold about you and your right of access can be exercised in accordance with the GDPR. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you and this information will be provided within 30 days from the time you requested.
If you have any questions or comments about our privacy practices, or wish to contact us for any reason, please feel free to email us through our Data Protection Officer at firstname.lastname@example.org
24. No error free performance
Last modified date: 10 April 2020