GDPR | TOP DRIVE CLUB

This Privacy Policy describes the protection of your personal data using the services of the Top Drive Club Internet portal at www.topdriveclub.com, the conditions for collecting personal data and handling them in accordance with the General Terms and Conditions and in connection with the purchase of a vehicle or other movable items.

Through this privacy policy we inform you about the protection of your personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as "GDPR"). AMILO Ltd. is fully aware of the importance of protecting the personal data and data of its customers and their employees and has always protected and will continue to protect these data and data. We feel committed to protecting your personal data and we respect your privacy. This policy describes our standards of protection regarding your personal data.

For ease of accessibility, this policy is posted online at:
https://www.topdriveclub.com/GDPR.

Wherever the General Terms and Conditions, the Purchase Agreement or other documents of our company refer to the Privacy Policy, the Personal Data Policy, the Processing Rules or a similar term, this Privacy Policy is intended.

I. Who collects your personal data?

We are the business company AMILO s.r.o., with registered office at Přímá 526, Prštné, 760 01 Zlín, ID No.: 48529214, a company registered in the Commercial Register maintained by the Regional Court in Brno, Section C, Insert 9873.

We are the operator of the Top Drive Club web portal at https://www.topdriveclub.com/. We are also a specialized importer and dealer of cars.

As the controller of your personal data, we will process your personal data according to the terms and conditions set out below.

II. Which data do we collect?

We only process personal data that you provide to us in connection with your use of our website, service contract, within your user account and in connection with the purchase of vehicles. We also declare that the collection of personal data is in any case limited as far as possible and restricted to only what is necessary.

We collect your personal data in an adequate, proportionate and limited manner necessary in relation to the purpose for which your personal data is collected and processed.

a) Data processed in connection with membership in TOP DRIVE CLUB

We collect data within your user account that you provide to us either when you register or edit your user account. These are mainly the following personal data:

data leading to your direct identification - basic identification data, which are mainly first name, last name, email and nickname;
your contact data, which is mainly your telephone contact, billing address and delivery address data.

Beyond the data from your user account, we collect data about your vehicle preferences so that we can offer you an adequate vehicle type.

b) Data processed in connection with the purchase contract

Within the framework of the purchase contract and the order, we collect the data you provide us with either when you create the order or when you fill in the data necessary to conclude the purchase contract for your vehicle purchase. This includes in particular the following personal data:

data leading to your direct identification - basic identification data, which are in particular first name, surname, date of birth, birth number and email;
your contact details, which are in particular telephone contact, billing address and delivery address data;
data about the subject of purchase, including the type and type of vehicle and its technical parameters.

c) Data processed in connection with the use of our website

Within our website we operate a search form for the purpose of selecting a specific vehicle and a form for asking questions

On the basis of the search form, we generally process only your selection preferences and the identification of your preferred selection parameters

Within the form for asking questions, we generally process the data filled in by you, namely:

data leading to your direct identification - basic identification data, which is mainly name
Your contact data, which is mainly telephone contact and email;
data entered in the question.

III. Why do we process your personal data?

For each of the areas of personal data we have specific and concrete reasons and purposes for processing.

The main reason why we process your personal data is so that we can fulfil our obligations under the service contract and deliver the service you have requested.

In some cases, we process your personal data in order to comply with legal obligations - for example, tax and legal obligations. Where you consent to this, we will also process your data for the purpose of sending you marketing offers.

IV. How do we secure your personal data?

We follow strict security procedures when storing and disclosing personal data. When storing your personal data, we ensure that it is always stored securely enough to minimise risks.

V. Who all will have access to your data?

We carefully select our partners to whom we entrust your data and who are able to ensure such technical and organizational security of your data. Our partners are bound by a duty of confidentiality and may not use the data provided to them for any purpose other than that for which we have made it available to them and for which we use it under this Privacy Policy.

The recipients of data who may have access to your personal data are thus:

people who handle your orders and are employees of AMILO s.r.o.;
people who provide us with the delivery of goods to you and the technical operation of certain services such as providing payments or operators of the technologies we use for our services;
persons who ensure sufficient security and integrity of our services and websites for us and also test this security on a regular basis;
persons to whom you provide legitimate access to your data and/or with whom you legitimately share this personal data;
providers of accounting, legal or administrative services.

VI. How long do we process your data and how is it secured?

We will process your data for the period necessary for performance under the contract and our legitimate interest, such as the proper handling of defect claims, etc.

We must process those personal data that are necessary to comply with all of our obligations under generally applicable law for the period of time specified by or in accordance with the applicable law (typically tax and accounting regulations).

Specifically, we process personal data for the following periods:

Data processed in connection with membership in TOP DRIVE CLUB are processed:
- for the duration of your membership and the existence of your profile;
- in the event of deletion of the profile or other removal of content, the data are stored for a maximum period of time for the exercise of mutual rights and obligations, and for a maximum period of fifteen years pursuant to § 636 para. 2 of the Civil Code.
Data processed in connection with the purchase contract are processed:
- for the duration of the rights and obligations under the purchase contract, including the periods necessary for the exercise of mutual rights and obligations, the exercise of rights of defective performance, default, liability for damages. This period shall not exceed fifteen years pursuant to Section 636 (2) of the Civil Code;
- for the duration of our legal obligations for the purpose of fulfilling our obligations in the field of taxes and other compulsory levies, which generally does not exceed 10 years.
Data processed in connection with the use of our website are processed:
- for a period of 3 years from the date of processing of your enquiry.

All personal data you provide to us is secured by standard procedures and technologies.

VII. What all rights do you have in relation to data protection?

In particular, you have the following rights in relation to your personal data:

the right to access personal data;
the right to rectify or complete personal data;
the right to request restriction of processing;
the right to object to or complain about processing in certain cases;
the right to request data portability;
the right to be informed of a personal data breach in certain cases;
the right to erasure of personal data (the right to be "forgotten") in certain cases; and other rights set out in the Data Protection Act and the GDPR.

You also have the right to apply to the Data Protection Authority for remedial action in the event of a breach of the obligations set out in the GDPR. Contact. However, in the case of manifestly unreasonable, inappropriate or repeated requests, we may charge a reasonable administrative fee for the exercise of the right in question or refuse such a request in accordance with the law.

If you wish to exercise and exercise any of the rights set out in the GDPR, please direct these exclusively to our contact email address: czech@topdriveclub.com.

VIII. Cookies

Our website may contain third party cookies which are used to obtain anonymous statistics about traffic and typical behaviour on individual pages. These third parties generally do not store any personal data in connection with the use of cookies, as they do not know the identity of the visitor to the site. These cookies are as follows:

Google Analytics - we use this service to obtain statistical information and Google may also retain the data collected for its own use in accordance with the Privacy Policy available at http://www.google.com/intl/cs/policies/privacy;
Tag Manager - Google sets cookies to analyse traffic on this website. Information about our use of our website is shared with Google for this purpose ( https://www.google.com/analytics/tag-manager/; https://policies.google.com/technologies/cookies?hl=cs)
Facebook Pixel - javascript code that allows us to measure, optimize and compile user circles for our communications (https://www.facebook.com/business/help/952192354843755)

IX. As Required by Law

We may disclose your personal information when required to do so by law in order to comply with a subpoena or to comply with the law, to protect your safety or the safety of others, to investigate fraud, or to comply with a judicial proceeding, court order, legal process served on the Company, or to secure and protect the Company's rights or property.

As set out in this Privacy Policy, we will not process your personal data without a lawful reason as defined in Article 6 of the GDPR. In general, we will process your personal data on the basis of the performance of a contract, the performance of a legal obligation and for the legitimate interests of the controller.

When we process your personal data for legitimate interests, we do so only if your data protection interests or fundamental rights and freedoms do not take precedence over those interests. These legitimate interests include, but are not limited to, delivering and continuing to develop and improve the website, learning from your behaviour on the website (website traffic) in order to provide a better service to you and other website users, helping you to change or improve the website and its content, obtaining information about what users do (and do not do) on our website and providing you with a stable, consistent and secure user experience associated with connecting to the website. These legitimate interests also include the processing of personal data for direct marketing purposes, for the prevention and detection of crime, and for the defence of your and our legal claims.

In order to also comply with any formal obligations under the GDPR, we provide information in accordance with Article 13(1) and (2) of the GDPR as follows:

Identity and contact details of the controller: Our client or AMILO Ltd, with registered office at Přímá 526, Prštné, 760 01 Zlín, ID No.: 48529214, a company registered in the Commercial Register maintained by the Regional Court in Brno, Section C, Insert 9873;
purposes and legal basis of processing:
1. Data processed in connection with membership in TOP DRIVE CLUB
  1. for the purposes of contract performance (in particular, the contract for the provision of services under the General Terms and Conditions and the performance of your rights under the user account);
  2. for the purposes of the legitimate interests of the controller (to inform you and offer you services and products of clients, i.e. to process your personal data for direct marketing purposes, to process personal data for the purposes of preventing and detecting crime, to defend legal claims, i.e. process your personal data within the scope specified in the contract, including contact and billing data)
2. Data processed in connection with the purchase contract
  1. for the purposes of contract performance (in particular the purchase contract);
  2. for the purposes of the legitimate interests of the controller (to inform you and offer you services and products, i.e. to process your personal data for direct marketing purposes, to process personal data for the purposes of preventing and detecting crime, to defend legal claims, i.e. to process your personal data within the scope of the contract, including contact and billing data);
  3. for the purposes of fulfilling a legal obligation (after the termination of the contract under the conditions and for the purposes set out in the applicable generally binding legal regulations, e.g. tax regulations, accounting and archiving regulations, regulations governing limitation periods, etc. )
3. Data processed in connection with the use of our website
  1. for the purposes of the legitimate interests of the controller and you (to respond to your enquiry, to inform you and offer you services and products, to process personal data for the purposes of preventing and detecting crime, to defend legal claims);
when we act as a controller, our legitimate interest under Art. 6 (1) (f) GDPR primarily for the legal protection of your and ours in case of any dissatisfaction or legal disputes and also in justified cases for direct marketing according to recital no. 47 of the GDPR
If you have given your consent, you can withdraw it at any time without condition at the contact details below.
The recipients may be external service providers connected with all the operation of our services and management systems as well as accountants, lawyers and consultants.
Personal data is not transferred to a third country or international organisation.
Personal data will be stored for as long as necessary to exercise any rights claims, namely the expiry of the limitation period.
If the processing of personal data is in breach of the GDPR you have the right to lodge a complaint with a supervisory authority. You can file a complaint, for example, at https://www.uoou.cz/stiznost.asp#obalhlava.
We do not carry out automated decision-making or profiling.

X. How to contact us?

If you have any questions about this Privacy Policy or questions regarding the deletion or modification of your personal data or withdrawal of consent, please feel free to contact us by email: czech@topdriveclub.com, or by mail to our contact address:

AMILO s.r.o.
Vídeňská 84
252 50 Vestec u Prahy
Czech Republic.

XI. Effectiveness

This Privacy Policy takes effect on the date of its publication on our website. We reserve the right to modify and update this policy.

The last update was on 26 October 2021.

AMILO s.r.o.
Přímá 526
760 01 Zlín - Prštné
ID: 48529214