1. Privacy policy of Auto 100 as 25 may 2018 The Privacy Policy (hereinafter: the Policy) informs the data subject about the data processing principles of Auto 100 AS (reg.No.11127264) and the rights of the data subject regarding his/her personal data.
2. Auto 100 AS processes the personal data of the data subject as prescribed by law, including the agreement entered into between Auto 100 AS and the data subject, legitimate interest or the consent of the data subject. Auto 100 AS provides the data subject with adequate information regarding the principles and extent of data processing. Personal data is processed within the legal basis for processing and to the minimum extent necessary to reach the purpose of processing.
3. Auto 100 AS ensures the correctness and transparency of the processed data. In order to guarantee these purposes, the data subject has the right to check the processed data and correct it, if necessary. Questions related to the protection of personal data, and the corresponding requests shall be handled by Auto 100 AS customer service agents at our showrooms or on telephone numbers published on our Webpage. We would prefer you to contact us with questions related to processing of personal data on the special e-mail address at: info@auto100.ee.
4. Auto 100 AS is part of Semler Gruppen A/S group. In order to comply with the contracts concluded with you and to improve your experience, the processing of personal data by Semler Gruppen A/S may be necessary. For these purposes, Auto 100 AS shall have the right to transfer personal data to the following third parties within Semler Gruppen A/S: Rohe Auto AS (reg.No. 11591048), Auto 100 [Latvian company], Auto 100 [Lithuanian company],  Auto 100 Premium (reg no: 16740742), SKO Motors OÜ (reg.No. 12458158), AS Adole Invest (reg.No. 10963053), Semler Baltic OÜ (reg.No. 12751289).
5. Auto 100 AS processes personal data on the basis of this Policy as the data controller, mainly for the sale and offering the sale of our products and services. Auto 100 AS has the right to process personal data as the data processor for third parties, such as producers of products and services on sale or representatives of leasing or insurance companies. When personal data is processed by other data controllers, their data processing privacy terms may apply. We advise you to examine these terms separately.
6. Auto 100 AS as a controller processes the personal data of the subject necessary for preparing the contract; identifying the partner; mutual compliance with the terms of the contract and additional obligations thereof, such as sales guarantee, after-sales guarantee, recalls; communication with government authorities, such as Road Administration, in order to execute the legal obligations of Auto 100 AS, and concluding legal issues and claims on the basis of the contract entered into with the data subject. For these purposes, the following data is processed: the name of the client and his/her representative, personal identification code, address, telephone number, e-mail address, vehicle and related services information, and information related to the execution of the corresponding obligations.
7. Auto 100 AS as a controller processes personal data on the basis of legitimate interest for the following purposes:
   1. a. to maintain and analyse the customer base to improve the range of services and products based on the results of the analysis as well as make better offers to the customer;
   2. b. to transfer personal data to the company conducting the customer satisfaction survey (currently AS EMOR, reg.No. 10076576 and Dive Eesti OÜ, reg.No. 11450019) for carrying out the customer satisfaction survey;
   3. c. to send advertisements and information materials of Auto 100 AS by post or e-mail (direct marketing).
   4. For these purposes, the following data is processed: the name of the customer and his/her representative, personal identification code, address, telephone number, e-mail address, vehicle and related services information.
8. Auto 100 AS strives to improve the range of products and services offered. In order to increase the quality of the services and experiences offered to data subjects, Auto 100 AS has the right to process other personal data in addition to those mentioned in this Policy. For the same reasons, Auto 100 AS may have to process data for other purposes than provided in this Policy. In the case of the need described in this article, Auto 100 AS ensures the legitimacy of the processing, and inform the data subject of such processing and the corresponding rights as prescribed by legislation.
9. Auto 100 AS acts as a reseller of products and services. Auto 100 AS also uses subcontractors for the sale of products and services. Therefore, transfer of personal data to our suppliers or subcontractors may be necessary or expedient in order to process the data within the extent prescribed by this Policy. Currently, Auto 100 AS transfers personal data for the above mentioned reasons to the third parties listed on webpage: https://retailers.skoda-auto.com/462/et-ee.
10. Auto 100 AS ensures that all third parties acting as data controllers for personal data transferred by Auto 100 AS on the basis of article 9 shall process the data strictly pursuant to the instructions given by Auto 100 AS and to the legal extent of data processing, as intended, to the minimum extent and in any other way according to the current data protection legislation.
11. Auto 100 AS shall store the data of the data subject until the purpose of processing is achieved or the basis for processing is withdrawn. Auto 100 AS does not, in any circumstances, store the data longer than the due date prescribed by legal enactments or until it is necessary for the purposes of concluding any possible claims and legal disputes. Auto 100 AS only stores the personal data longer than 10 years in the case of relevant legal basis or legitimate interest.
12. The data subject shall have the following rights, taking into account the limits for exercising these rights pursuant to the terms of data protection law:
    1. to receive information about the personal data processed;
    2. to correct inaccurate personal data;
    3. to request deletion of personal data;
    4. to request limitation of personal data processing;
    5. to object to personal data being processed;
    6. to receive information about the right to transfer data;
    7. to decline further processing.
13. In order to exercise the rights prescribed by Article 12 Auto 100 AS kindly asks you to submit your request to the contacts indicated in Article 3 of this Policy. We also ask you to submit your questions related to the processing of personal data by third parties authorised by Auto 100 AS to the same contacts.
14. In the event that the data subject has refused the processing of personal data, the transfer of personal data or has requested limitation or deletion of personal data, Auto 100 AS may not be able to provide the data subject with the contractual services. In this case, Auto 100 AS has the right to refuse fulfilling the obligations prescribed by the contract and/or terminate the contract entered into between Auto 100 AS and the data subject unilaterally.
15. The customer has the right to submit a claim to the Data Protection Inspectorate or court if the customer finds that Auto 100 AS processes their personal data unlawfully or otherwise violates their rights.
16. The present Privacy Policy is valid as of 25 May 2018. Auto 100 AS may change the Policy by introducing a new full version of the Privacy Policy.