Privacy Policy

1. Introduction

This privacy statement applies to the processing of personal data by Carsub B.V. (“Carsub” or “we”). Carsub has its registered office in Almelo and has its office at Wierdensestraat 2, 7607 GH in Almelo. Carsub is registered with the Chamber of Commerce under number 82210365. Under the General Data Protection Regulation (“GDPR”), Carsub qualifies as a so-called data controller. Carsub therefore also wishes to inform you about the personal data we have about you and how we deal with it.

If you have any questions about this privacy statement or about the processing of your personal data, you can fill out the contact form and/or send an email to Carsub via the Carsub website.

Carsub treats all personal data it obtains in accordance with the GDPR and all other applicable privacy laws and regulations. Through this privacy statement, Carsub informs you about how Carsub handles your personal data. This privacy statement is intended to provide you with answers to the following questions:

Who is the controller with regard to your personal data? (see: 1)
How do we receive your personal data? (see: 2)
What personal data is obtained? (see: 3)
On what basis and for what purpose do we obtain your personal data? (see: 4)
Who has access to your personal data? (see: 5)
What are your rights with regard to your personal data? (see: 6)
How long will we keep your personal data? (see: 7)
What protective measures do we take? (see: 8)

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2. Reception

Carsub receives your personal data when you visit our website carsub.nl and al subdomains of carsub.nl, when you fill out an application form and/or a contact form on our website, when you subscribe via our website or purchase other products or services from us, and when you contact one of our employees, for example via email, telephone or social media channels.

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3. Personal Data

With regard to the purposes set out in point 4, Carsub may collect and process the following categories of personal data about you:

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• identification information, such as your name and date of birth;
• contact information, such as your address, email address, and phone number;
• additional information, such as your ID and driver's license;
• financial information, such as your bank account number;
• Carsub account information, such as your customer number and order history;
• location data via a GPS tracker in your car;
• all other personal data that we receive from or about you or that we can obtain ourselves and that we use for the purposes set out in point 4.

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If you want to make use of the option to appoint an additional driver for your car, Carsub also collects and processes the above personal data from that driver. In addition to the personal data mentioned above, Carsub can also collect and process information obtained via the website or the device you use to visit our website. This may include:

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• location data;
• data via other websites, for example when you visit the Carsub website via Facebook or other social media channels (for the sake of completeness, Carsub draws your attention to the privacy statements of these parties). Carsub is not responsible for its content. Should you end up on a third party's website via the Carsub website, please also carefully review the privacy statement and other terms and conditions here).

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4. Legal grounds and purposes

According to the GDPR, we are only allowed to process your personal data if we have a legal basis for doing so. In addition, we may only use the personal data for the purposes for which we obtained it. We can process your personal data on one of the following grounds:

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• we need your personal data to execute the agreement that we want to enter into with you or that already exists between us;
• the processing of your personal data by us is necessary for us to comply with the legal obligations that lie on us;
• we process your personal data because it is necessary to protect our legitimate interests.

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We collect your personal data for the following purposes:

• to be able to deliver the products or services you have ordered;
• to respond to your questions about our products or services and to provide you with information about our products or services;
• to be able to execute an agreement that is and/or has been entered into between us;
• to verify that your identity and financial information are accurate in connection with providing our products or services;
• to be able to track our cars at all times to prevent our cars from being stolen;
• to improve our products and services;
• to be able to investigate and follow-up complaints about our products or services;
• to comply with legal obligations;
• to be able to send newsletters and/or emails with offers or information about our products and services that may be of interest to you;
• to be able to represent our legitimate business interests.

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5. Recipients of your personal data

In some cases, Carsub may share your personal data with third parties, such as the administrator of our website, marketing platforms and distribution and logistics partners. These parties only obtain your personal data to the extent that this is strictly necessary for the execution of their work. Third parties to whom Carsub provides your personal data are also responsible for processing that data and for compliance with the GDPR. If a third party processes your personal data as a processor on behalf of Carsub, we will conclude a processing agreement that meets the requirements of the AVG.
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If you have submitted a subscription request to us, your personal data will be shared with a company that, among other things, checks the creditworthiness of our customers, called RentalCheck, for the execution of the agreement with Carsub. RentalCheck hereby qualifies as a processor within the meaning of the GDPR. We will also share your data with the provider of the car you will be driving. The identity of this provider is made known via the order confirmation that you receive. Furthermore, your bank details will be shared with the payment platform that is enabled by Carsub, namely Online Payment Platform.
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Carsub will not share your personal data with companies located outside the European Economic Area. Carsub will not sell or otherwise provide your personal data to third parties for a fee.

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6. Your rights

Under the GDPR, as a data subject, you have the following rights, which you can exercise by sending an email to Carsub:

• Data portability: You can request that we transfer your data to a third party.
• Forgetfulness: You can request that we delete your data.
• Objection: You have the right to object to our processing of your personal data.
• Restriction: You can request that we restrict processing.
• Rectification: you can ask us to change and/or supplement your personal data.
• Access: you can request insight into the personal data that we have about you.

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Requests regarding your personal data can only be submitted by you. Carsub can therefore ask you to reveal your identity in order to assess whether the request is lawful.

Carsub may refuse your request for access if access violates other individuals' right to privacy, for the protection of trade secrets or for the protection of intellectual property. If your data is required to implement an agreement or legal obligation, it is possible that we cannot delete your data (yet). If you have a complaint about how Carsub handles your personal data, you have the right to file a complaint with the Data Protection Authority.

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7. Retention period

Your personal data will be kept by Carsub for as long as necessary with regard to the purpose for which it was obtained, or as long as necessary under our legal obligations (such as the tax retention obligation of at least 7 years). Since it is not inconceivable that Carsub will provide you with services and/or products again in the future, we will not destroy the customer base and therefore your personal data over time. We will (continue to) take appropriate organizational and technical measures to protect your personal data. In addition, you can always exercise your rights as described under point 6 of this privacy statement.

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8. Protection

Carsub takes the protection of your personal data very seriously and takes appropriate organizational and technical measures to prevent loss, misuse, unwanted disclosure, unauthorized access and unauthorized modification.

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9. Changes

Carsub reserves the right to change this privacy statement at any time. If the privacy statement changes, it will replace the previous version and take effect automatically.

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