Privacy Policy regarding the processing of personal data

Introduction

The General Data Protection Regulation (or GDPR for short) is a positive step for individuals who have more control over how their personal data is used. On May 25, 2018, this new legislation came into force and we changed a series of processes and policies to prepare our business. We consider ensuring the right to the protection of personal data as a fundamental commitment of TH Trucks, therefore we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679.

This statement describes what types of information we collect from you, how it is used by us, how we transfer it to third parties and to which third parties, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited emails, communication messages or share your data with anyone else. We do not sell your information to third parties, but we work closely with selected partners to help us provide the information, products and services you request from us. For example, our partners, the direct manufacturers who provide us with the documentation for your vehicles.

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes to the way we process your personal data or any changes to legal requirements. In the event of any such changes, we will display the modified version of the Privacy Policy on our website, for which reason please check the contents of this Privacy Policy periodically.

We believe that the protection of your personal data and the transparency of how your data is used by us are of great importance. Therefore, we have prepared this statement to inform you about how we handle your personal data.

We inform you in this statement about:

• What personal data we collect from you;
• For what purpose are these data used by us;
• What is the legal basis that allows us to use this data;
• What are the third parties to whom we transfer your data;
• How we protect your personal data; and
• What rights do you have regarding your personal data?

 

This privacy statement applies to personal data collected by entities and subsidiaries of TH Trucks, including entities of our DAF partners. When we collect personal information from you in a context other than this website, we provide more specific information, as necessary, in addition to the information provided in this statement.

We take all reasonable steps possible to make this statement as concrete and complete as possible. Please do not hesitate to contact the Data Protection Officer (DPO) if you have any questions or concerns regarding this statement: dpo@thtrucks.ro

 

Our commitment to your privacy

We are committed to carefully managing your personal data. We use the data in accordance with the appropriate security standards and delete it as soon as we no longer need it. We only collect the personal data we need to achieve the purposes that have been communicated to you. Finally, we make sure your data is accurate and up to date.

Who we are, who is responsible for the processing of your personal data and how you can contact us

TH Trucks SRL, legal entity, having its registered office in Gilau, Cluj County, Principala street, no. 1333, registered in the Trade Register under no. J12/2088/1997, unique fiscal registration code RO9951956 (hereinafter referred to as “TH” ). For the purposes of data protection law, we are the controller when we process your personal data.

TH Trucks and its subsidiaries (offices) TH Trucks are the operators regarding the processing of your personal data. This privacy statement contains contact details if you wish to exercise your rights regarding the personal data we have collected from you. In this statement, “TH”, “we” and “our” refer to TH Trucks and subsidiaries (working points) TH Trucks SRL.

As we are always open to find out your opinions, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact the TH Data Protection Officer at dpo@thtrucks.ro , by mail or courier to the address Principala street, no.1333, town of Gilau, Cluj County – with the mention : to the attention of the TH Data Protection Officer, Valentin Voica.

 

What categories of personal data we process, on what basis and in what cases

We collect information about you and your vehicle when you interact with our website, through applications or production partners who ask us to contact you when you place an order. We collect only the information necessary, relevant and appropriate to the purpose for which you provide it.

 

Target people		Type of personal data	Purpose	Legal basis
Individual customers		Name and surname, domicile/delivery address, telephone number, e-mail address, and, if necessary, identity card number, copy of identity card, personal numerical code, bank account number, Apart from the personal data mentioned, in the case of car service offered to individual customers, the following national/international identification numbers associated with the vehicles owned by them and which make a person identifiable are also processed: – license plate; – chassis series/vehicle identification number;	Concluding and executing a contract for the sale and delivery of products and services, including purchases in the online store. Compliance with legal requirements. Building and maintaining customer relationships. Information about products and services that may interest you. Market research and business analysis Participation in loyalty programs. Participation in surveys and training. Service and assistance, assistance with road failures, warranty, field operations and service actions.	Contractual obligation. Legitimate interest.
Legal representatives of clients, legal entities, their employees, delegates, proxies, drivers, etc.,	Name and surname, position, telephone number, e-mail address, and, only if necessary, identity card number, copy of identity card, personal numerical code. In addition, in the case of drivers who call for service and assistance in case of accident, vehicle identification number (chassis request), vehicle registration number, GPS coordinates, date and time, driver’s code.		Concluding and executing a contract for the sale and delivery of products and services, including purchases in the online store. Compliance with legal requirements. Building and maintaining customer relationships. Information about products and services that may interest you. Market research and business analysis Participation in loyalty programs. Participation in surveys and training. Service and assistance, assistance with road failures, warranty, field operations and service actions. Vehicle performance analysis and optimization of the quality and performance of our products and services. Performing remote diagnostics and repairs, as well as maintenance planning. Providing assistance in the event of a road accident when called by ITS. Fulfillment of contractual obligations.	Contractual obligation. Legitimate interest
Visitors of web pages belonging to TH Trucks SRL	Name and surname, delivery address, telephone number, e-mail address, user ID, browsing history and browser settings, for example, pages visited, date and time of visit and location, IP address and device from which visited the website		Providing access to IT systems, online stores and portals.	Legitimate interest Contractual obligation
Candidates applying for jobs opened in TH Trucks and published on the company’s websites based on a recruitment form	Name and surname, telephone, e-mail address, date of birth		Interview planning Recruitment of new employees	Legitimate interest consent

 

 

 

Below is an overview of the types of personal data we process. We also provided the purpose of using this data and the legal basis for processing.

If we process your data in a manner substantially different from that specified below, we will inform you of it separately.

Target people

Other types of information we collect:

1. Vehicle information (including license plate number, chassis series, service reminders, mileage and warranty repair information;
2. The date and time you used our services;
3. Information about cookies, pixels or beacon;
4. The address of the website from which you accessed our website;
5. Details of any transaction between you and us;
6. If you work with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size, and company details;
7. Voice recordings of calls you make to our customer service center;
8. “Live chat” recordings;
9. Within your Personal page from the online sales platform with the desired product, delivery address, billing details, data about the payment method as well as card or bank account data.
10. Any information in the correspondence you send us.

 

We also offer the possibility to register on the TH Trucks platform through your Facebook, Google, Youtube or any social networking account. If you opt for one of these, you will be directed to a page managed by the operators of the social networking site, where they will inform you about the transfer of your data to TH Trucks. You can consult the privacy policies of social networking sites by accessing the links on the web pages of the owner companies.

We also collect data from public sources

Please note that we also collect data from (public) sources, such as credit bureaus, chambers of commerce, etc.

How long do we keep your personal data?

We store your personal data for as long as is necessary for the purposes for which we collected it, for the period permitted by law and defined by our internal data retention policies.

Other purposes of data processing and how we may use this information

TH Trucks will use the information for the following purposes:

• To be able to process your request in the case of a service order, sales order, a business partnership or in other cases;
• To include you in a list of prospective clients, candidates (portfolio) if you have allowed this;
• To inform you about different campaigns, products and services, job vacancies;
• To prepare statistical data on various topics of commercial interest, including vacancies;
• In the legitimate interest

We will only process the information necessary for the purpose for which it was collected when accessing or creating a user account on the TH sites. You will always have the option not to receive marketing communications from us (and you may withdraw your consent or object at any time). We will never send you unsolicited emails, communication messages or share your personal information with anyone else.  

There are various ways we can use or process your personal information. We list them below:

Consent:

If you have given your consent, we may use and process your information to provide the latest information on the offers you have requested or wish to request:

• Prospective customers for vehicles
• Prospective customers for parts and tires
• Prospective customers for the services offered by TH Trucks

 

Contractual basis:

We may use and process your personal information where necessary to enter into a contract with you and to fulfill and complete your orders, purchases and other transactions with us.

• Existing customers (contract)
• Telephone, electronic or personal communication on the customer satisfaction index

We may use and process your personal information as set out below, where it is necessary for us to conduct activities for which it is in our legitimate interest as a business to do so.

• Existing customers of vehicles purchased or in the process of purchase or simply for details on the products, articles or services performed by TH Trucks
• Customers of parts and tires or potential customers for and about products, articles or services performed by TH Trucks
• Existing service customers (without contract) in order to obtain technical information

 

Legitimate interest

If necessary, we will contact customers or authorized persons (those who have been active for the last two years) with sales messages regarding our latest offers or former customers in the event of a new collaboration.

Through an assessment of the legitimate interest we have established that this is in the interest of all customers or partners.

We may also collect and further process information about your behavior while visiting our website or using your smartphone to personalize your online experience and provide you with offers tailored to your profile. we invite you to find out more details in this regard by consulting the section on the purposes of processing below.

On our website and in the smartphone application we can store and collect information in cookies and similar technologies, according to the Cookies Policy.

We do not collect or otherwise process sensitive data, included in the General Data Protection Regulation in special categories of personal data. We also do not want to collect or process data on minors under the age of 16.

For Marketing we want to keep you informed about the best offers for the products/services that interest you. In this regard, we can send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) Containing general and thematic information, information on products similar or complementary to those that you have purchased them, information about offers or promotions, information about products of interest In order to provide you with information of interest to you, we may use certain data regarding your buyer behavior (eg the products viewed/added to wishlist/purchased) to create a profile. We always ensure that such processing is carried out in compliance with your rights and freedoms and that the decisions taken on the basis of them have no legal effect on you and do not affect you in a significant way.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

– Changing the settings in the client account;

– Accessing the unsubscribe link displayed in the messages you receive from us; or through

– Contacting TH using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any case where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop the processing of your personal data for marketing purposes, and we will process your request.

To defend our legitimate interests

There may be situations in which we use or transmit information to protect our rights and business. These may include:

– Measures to protect the website and users of TH online platforms from cyber attacks:

– Measures to prevent and detect fraudulent attempts, including the transmission of information to the competent public authorities;

– Measures to manage various other risks.

The general basis of these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases we base the processing on legal provisions such as the obligation to ensure the protection of goods and values ​​provided by the applicable legislation in this matter.

As long as we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the TH Trucks platform or the platforms we manage. You may ask us to delete certain information or close your account at any time, and we will respond to such requests, subject to the retention of certain information, including after closing your account, where required by applicable law or our legitimate interests.

To whom we transfer your Personal data

We transfer information about you to TH affiliates (including TURBOS HOET, POLIMOB SRL, ICS CAMIOANE SRL, TURBOS HOET ROMANIA SRL) who are subject to the same data protection standards, but also business partners such as:

– Strategic suppliers of products and goods (DAF TRUCKS NV, PACCAR, VDL, etc.)

– IT providers

– Service providers

– Insurance companies

– Banks (Raiffeisen Bank, Unicredit Bank, Banca Transilvania, BRD)

– Auditors (MAZARS)

– Authorities (public authorities, courts, lawyers, bailiffs, investigative bodies)

How do we protect your personal data in relation to third parties that are not subject to European data protection rules?

No personal data will be transferred to third parties who do not apply personal data protection policies.

In other cases, we may transmit or provide access to certain personal data of yours to the following categories of recipients:

– companies within the same group of companies as TH Trucks;

– TH Trucks Marketplace partners;

– courier service providers;

– payment/banking service providers;

– marketing/telemarketing service providers;

– market research service providers;

– other companies with which we can develop joint programs for offering our goods and services on the market.

If we have a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities.

We ensure that access to your data by third parties under private law is made in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.

In which countries we transfer your personal data

We currently store and process your personal data in Romania.

However, we may transfer certain of your personal data to entities located in the European Union or outside the Union, including in countries for which the European Commission has not recognized an adequate level of protection of personal data.

We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other guarantees, such as standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data. transferred from within the EU to the United States.

You can contact us at any time, using the contact details set out above, to find out more about the countries in which we transfer your data, as well as the guarantees we have put in place regarding these transfers.

How we protect the security of your personal data

We take care to protect the availability, integrity and confidentiality of your personal data. We have implemented a number of security measures to ensure the protection of your data. For example, we implement access controls, use appropriate network and system security measures, such as firewalls, install patches, and protect mobile devices with appropriate passwords.

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.

The transmission of your personal data is done using encryption algorithms and we store them on secure servers, while ensuring data redundancy.

Any payment information is encrypted using state-of-the-art innovative technologies.

Despite the measures taken to protect your personal data, we warn you that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, there is a risk that the data may be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities in systems that are beyond our control.

What rights do you have?

When we process your personal data, you have certain rights that you can exercise at any time. We offer below an overview of these rights and what they mean to you. You can exercise your rights by contacting dpo@thtrucks.ro

Rights that may be exercised by data subjects in connection with the processing of their personal data by TH Trucks SRL:

Any data subject is guaranteed the exercise of the rights provided by the GDPR, respectively:

1. a) theright of access: thepersons concerned can obtain from TH Trucks SRL the confirmation that they are processed

personal data, as well as information on the specifics of the processing such as: purpose, categories of personal data processed, recipients of the data, period for which the data are kept, the existence of the right to rectify, delete or restrict the processing.

This right allows data subjects to obtain a free copy of the personal data processed, as well as for any additional copies;

1. b) theright to rectification of data: the datasubjects may request TH Trucks SRL to modify the data

incorrect data concerning them or, as the case may be, to complete data that are incomplete;

1. c) the right of deletion: data subjects may request the deletion of their personal data when:

• they are no longer needed for the purposes for which we collected and processed them;
• the consent for the processing of personal data has been withdrawn and TH Trucks SRL can no longer process them on other grounds;
• personal data are processed against the law;
• personal data must be deleted in accordance with the relevant legislation;

1. d) theright to withdraw consent: the data subjects may withdraw their consent at any time regarding the processing of personal data processed on the basis of consent. Withdrawal of consent does not affect the legality of processing carried out prior to this time.

 

1. e) theright of opposition: the persons concerned may at any time oppose the processing for marketing purposes, as well as the processing based on the legitimate interest of TH Trucks SRL, for reasons related to their specific situation;

 

1. f) theright to restrict the processing: data subjects may request the restriction of the processing of their personal data if:

• challenges the correctness of personal data, for a period that allows us to verify the accuracy of the data in question;
• the processing is illegal, and the data subject opposes the deletion of personal data, instead requesting the restriction of their use;
• we no longer need the data for processing, but the data subject requests it for a lawsuit;
• if the data subject has objected to the processing, for the period of time in which it is verified whether the legitimate rights of TH Trucks SRL as operator prevail over the data subject’s rights.

1. g) theright to data portability: the data subjects may request, in accordance with the law, that TH Trucks SRL

provide them with certain personal data in a structured, frequently used and automatically readable form. If the data subjects request it, TH Trucks SRL can send the respective data to another entity, if technically possible.

1. h) theright to submit a complaint to the National Authority for the Supervision of Personal Data Processing: the data subjects have the right to submit a complaint to the National Supervisory Authority for the Processing of Personal Data if they consider that they have been rights violated:

National Authority for the Supervision of Personal Data Processing,

Address: B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania

anspdcp@dataprotection.ro

 

For the exercise of the rights mentioned in points a) – g) above, or for any questions about the processing of personal data by TH Trucks SRL, data subjects may use the contact details of the data protection officer designated by TH Trucks SRL, by sending application:

– by e-mail to: dpo@thtrucks.ro

or

– by post or courier to the address: Principala street, no.1333, town of Gilau, Cluj County

 

Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make all reasonable efforts to resolve any issue amicably.

Cookie

We use cookies on this website. More information on this topic is available at this link.