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LOGIN POLICY
aiMotive Ltd.
Effective from 05 July 2018

1. Introduction and the purpose and scope of this policy

The purpose of this policy is to set out the terms and conditions under which AImotive Informatikai aiMotive Korlátolt Felelősségű Társaság (hereinafter: “aiMotive”) as data controller may process personal information (hereinafter: “Login data”) in connection with the Insights section of its following website [aimotive.com; hereinafter: “Section”]. Personal information may be collected from individuals (the data subjects) using the internet to access documents, videos and other types of content provided by aiMotive and uploaded to the Section.

The access of the Section necessitates the processing of the personal data detailed in section 4 of this policy. This data processing falls under the scope of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter: “GDPR”).

aiMotive is dedicated to protecting privacy and personal data and strives to put in place the necessary measures for this purpose. In order to ensure compliance with the underlying legal regulations and to eliminate, to a reasonable extent, potential negative consequences of the data processing, aiMotive hereby sets out the rules on the processing of the personal data by aiMotive, as well as the rights and remedies of individuals affected by aiMotive’s processing of their personal data in the course of accessing the Section. aiMotive shall publish this policy on its website and update it as applicable and when necessary (e.g. due to a change in aiMotive’s activities or in laws).

This policy covers the processing of personal data by aiMotive in connection with the Login data, including monitoring the user’s activity while accessing the Section. The terms of this policy shall be in addition to, not exclusive of or in substitution for the rights and remedies of individuals under the applicable mandatory legal regulations, especially the GDPR.

2. Legal basis of data processing

For the purposes set out in section 4 of this policy, aiMotive collects and processes the information (including personal data) as per section 6 of this policy from and about individuals and stores it in its files (which may include written, printed and electronic form).

The legal basis of the processing of Login data under this policy is the explicit and informed consent of the data subject given in line with Section 6 (1) a) of the GDPR.

3. Details of the data controller

The data controller in respect of personal data handled under this policy is as follows:

• Name: AImotive Informatikai Korlátolt Felelősségű Társaság
• Seat: 1025 Budapest, Szépvölgyi út 22.
• Company reg. no.: 01-09-208015
• Tax no.: 25316663-2-41
• Telephone no.: +36-1-770-7234
• Website: https://aimotive.com
• E-mail: info@aimotive.com
• Primary Contact: Head of Legal Department
• Data Protection Officer: David Végh

4. Categories of processed personal data, purpose and legal basis of data processing, data retention period

aiMotive highlights that the consent to the data processing is voluntary, however the processing of the above personal data is necessary in order for the data subject to be able to access the Section. Failure to provide consent results in no detrimental consequence to the data subject, but the content of the Section will not be accessible in this case.

5. Persons with access to personal data

Login data processed by aiMotive under this policy may be accessed by the following persons at aiMotive (as applicable from time to time), on a need-to-know basis:

• IT department; technical implementation, troubleshooting, monitoring
• Commercial Team; technical implementation, user support, monitor content and usage statistics

- Chief Commercial Officer

- Head of Business Development

• Business Development Managers

- Head of Marketing and Communications

• Marketing Managers

6. User tracking, marketing contact and profiling

The informed and explicit consent of the user extends to the tracking of downloads they complete while accessing the Section and use this data to provide a personalized marketing experience. This tracking forms and integral part of the data processing specified in section 4.

We will use the tracking results to provide users with custom-tailored e-mails, messages and newsletters and other information the content of which will be based on their previous downloads. The impact of this on users is that they will only receive the content that is deemed relevant to them on the basis of their downloads. aiMotive employees may reach out directly to users based on their interests with further information, business opportunities and offers.

The database tracks user interactions with the page through the use of cookies. The login cookie will store information on the login status of the user, and download link clicks will be paired with this login information. The compiled database is stored by aiMotive in its entirety and not shared with any third parties. For more information on the cookies we use please read the aiMotive Cookie Policy.

7. Tools used to process collected data

aiMotive will use the tools specified below to collect and process the user data provided under this policy. More information on the types of data collected and how that data is collected is provided below in sections 7a and 7b respectively.

1. Internally developed user registry and tracking system (database)
2. Salesforce Customer Relationship Manager (CRM)

7a. Information collected and stored in the Internally Developed User Registry and Tracking System

The database is used to implement basic login functionality on the aiMotive website. User data is provided through oauth authentication by LinkedIn or Microsoft accounts. The user is requested to confirm the data shared by these services. On completing oauth authentication the user is presented and asked to review the data collected by aiMotive under this policy. This data includes:

• Full name
• E-mail address
• Current employment
• Location of current employment

The user is free to modify the data collected from the above-mentioned third-party services before submitting it to the aiMotive database.

aiMotive draws the user’s attention to the fact that user downloads are actively monitored when logged in (e.g. if a user downloads document one, the database is updated to reflect this). Members of our team will periodically review the downloads users have made to provide a tailored sales and marketing experience. Only interactions with downloads are monitored and all other statistical data is collected in bulk form by Google Analytics.

7b. CRM

aiMotive uses the CRM tool to manage and track sales prospects and partner relations. User data is sent to the service automatically when the user submits their information through the review form.

The CRM is a third-party cloud service. User information stored therein falls under the Salesforce Privacy Policy which can be read here: www.salesforce.com/eu/company/privacy

Tracking data collected and stored in the database is not shared with the CRM and remains on aiMotive servers.

8. Rights of the data subject

The data subject may request from the data controller access to personal data concerning the data subject, rectification of inaccurate personal data, erasure of personal data, and in certain cases, restriction of processing. Additionally, the data subject is entitled to the right to data portability, to lodge a complaint with a supervisory authority and to an effective judicial remedy. In the case of profiling, the data subject is entitled to the right to obtain human intervention on the part of the data controller and to express his/her point of view and contest the decision.

• Right to access

The data subject is entitled to request information at any time about whether and how the data controller processes their personal data, including the purposes of data processing, the recipients to whom the data was disclosed or the source where the data controller received the data from, the envisaged period for which the personal data will be stored, the rights of the data subject concerning data processing, information concerning automated decision making, profiling, and information concerning related guarantees in the case of forwarding personal data to third countries or any international organization. When exercising the right to access, the data subject is also entitled to request copies of the personal data undergoing processing; in the case of a request submitted electronically, the data controller provides the requested information electronically (in .pdf, .xls or other similar format).

• Right to rectification

At the request of the data subject, the data controller corrects or completes personal data concerning the data subject. If any doubts arise concerning the corrected data, the data controller may request from the data subject the certification of the corrected data primarily with documents.

• Right to erasure ("right to be forgotten")

If the data subject requests the erasure of any or all personal data of theirs, the data controller shall erase such data without undue delay if:

• the data controller does not need the personal data in question any more for the purpose such data was collected or otherwise processed for;
• it concerns data processing that was based on the consent of the data subject, but the data subject withdrew the consent and the data processing has no other legal basis;
• the data controller illegally processed the personal data; or
• the deletion of personal data is necessary for the performance of legal obligations.

• Right to restrict data processing

The data subject can request the restriction of the processing of their personal data in the following cases:

• the data subject contests the accuracy of the personal data;
• the data processing is unlawful but the data subject opposes the erasure of data, requesting the restriction of the usage of the same instead;
• the data controller does not need the personal data for data processing purposes any longer but the data subject needs the data for the establishment, exercise or defense of legal claims.

• Right to data portability

The data subject is entitled to request that the data controller hands over the personal data of the data subject provided to the data controller on the basis of consent or a contract, and processed by the data controller by automated means to the data subject in a structured, commonly used and machine-readable format.

• Right to lodge a complaint, right to an effective judicial remedy

If the data subject considers that the processing of their personal data by the data controller infringes the provisions of the established data protection legal regulations, especially the GDPR, the data subject has the right to lodge a complaint with the competent data protection supervisory authority. In Hungary, this authority is the Hungarian National Authority for Data Protection and Freedom of Information.

9. Third party data processors

Login data may be transferred to companies within AImotive’s group (AImotive Inc, having its business address at 1907 Colony Street Mountain View, CA, 94043 USA; AImotive GmbH, having its business address at c/o Cormoran GmbH, Am Zirkus 2, 10117 Berlin). Login data is shared with the above-mentioned third-party CRM.

10. Data Security

Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorized purposes) of the personal data. Opportunities for unauthorized processing of personal data, and against the accidental loss of, or damage to, personal data will be enforced by putting in place appropriate hardware and software-based security measures.

11. Miscellaneous

This policy takes effect on the day on which it is issued and remains in force until its withdrawal or replacement by aiMotive. aiMotive shall review this policy on a regular basis and align it with respect to the changed circumstances, as it deems appropriate.

12. Automated Decision Making, Profiling

No automated individual decision-making nor profiling is performed in the course of the data processing of the Data Controller concerning the Data Subject.