Ayvens understands your concerns regarding the confidentiality of your personal information. Below we describe how we acquire and use that information and outline your rights. Please read this carefully, so that the process is as fair, transparent and secure as possible. The following principles are central to how we process your personal information:

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  Transparency and fairness: When we collect and process your personal information, we inform you as to who collects and receives these data, and the reasons for this. When required by law, we always seek your prior consent (e.g. before collecting any sensitive information or sending any direct marketing material). We never use your personal information for purposes that are incompatible with the purposes outlined here.
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  Legitimacy: Ayvens does not collect or process personal information without a lawful reason. We use your personal information only for appropriate business purposes (e.g. to provide services, manage relationships with customers, manage customer vehicle fleets, and perform accurate invoicing, or for marketing activities, profiling to better serve customers, to conduct satisfaction surveys or draft reports and comply with our legal obligations).
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  Minimization: We only collect the personal information strictly necessary for data processing, as set out in this document. We collect sensitive information only where relevant. We take all reasonable measures to ensure that your personal data on record is accurate, complete and up to date.
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  Privacy: We endeavor to ensure privacy when implementing personal data processing. To this end we also carry out privacy impact assessments to ensure that our safeguards are appropriate and that your information is protected.

**2. About us

ALD Automotive S.R.L.** is a limited liability company organized and existing under the laws of Romania, seated in Bucharest, 1st District, 1-7 Ion Mihalache Blvd., 3rd Floor, registered with the Trade Register Office under no. J40/20912/15.12.2004, Fiscal Registration No. RO17043227 , trading under the brand Ayvens and hereinafter referred to as “Ayvens”, “we”, “our” or “us”. This Privacy Policy only relates to processing undertaken by or on behalf of Ayvens. Whilst our websites may contain links to other third party websites, we do not accept any responsibility or liability for those third parties' policies in relation to any personal data or their collection or processing of any personal data.

**3. How we use your personal data and which personal data is used ** We carry out, as data controllers or even joint data controllers, a few processing operations involving personal data that are necessary for the proper conduct of our business. In this respect, we listed below the purposes for which we carry out processing activities:

4. How do we collect your data

We collect your personal information either directly from you (e.g., through our call centers, if you make a request, when you create an account on one of our platforms or make a purchase), or passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. from our business partners or social media platforms).

5. Are you required to provide your personal data

Granting your consent and providing your personal data is entirely voluntary in all cases where processing is based on consent; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which we cannot take action without certain personal data, for example because this personal data is required to process your inquiries, your orders or provide you with access to an offering or newsletter. In these cases, it will unfortunately not be possible for Ayvens to provide you with what you request without the relevant personal data.

6. How long do we keep your personal information

Personal data is kept by Ayvens, in an active base, for the time necessary to achieve the objective pursued at the time of their collection.

The retention period is therefore initially set by Ayvens according to the operational needs necessary for the execution of each individual rental contract and taking into consideration any recommendations of the local Data protection authority.

However, certain longer retention periods may result from legislative and regulatory texts. Some laws also require that documents/information containing personal data be retained for a specific period of time for evidentiary purposes or in anticipation of possible litigation until the action in question is time-barred. For example, in commercial matters for accountability documents, obligations are in principle prescribed by five years if they are not subject to special prescriptions. Ayvens is therefore obliged to keep certain personal data beyond the execution of the lease contracts, even though it no longer has any use for them, in the form of so-called intermediate archives.

At the end of these periods, the personal data is:

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  Anonymized; and/or
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  Purged.

7. Who Ayvens may share your personal data with

Ayvens understand that you do not want us to provide your personal information directly to third parties for their own marketing purposes without your consent. However, Ayvens occasionally need to use partners or processors to provide you with the requested services and a better experience, for the purposes described above. We therefore limit our sharing of your personal information on a need-to-know basis as follows: • with internal business departments such as sales, customer care/quality department, marketing, IT services, support and maintenance. Inside the Ayvens Group/ SG Group, we may share your personal data with other Ayvens entities, who may only use your personal information in compliance with this Policy. • with our service providers, such as data hosting service providers, data administrators, located in France or within the European Economic Area and instructed to only use your personal information in accordance with our instructions. • with unaffiliated partners, such as Banks, insurers, vehicle constructors, marketing partners, actors of mobility etc. • where needed to affect the sale or transfer of business assets, in connection with a bankruptcy proceeding, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. • when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.

8. Export of personal data outside of the EEA

In general, all of the Ayvens databases are located inside the European Union. However, Ayvens may transfer your personal data from the Europe to countries within or outside the European Economic Area. The countries outside of the EEA may not provide the same level of protection as is available in the EEA. If we transfer your personal data outside the EEA, we will ensure that adequate levels of protection are in place in relation to the processing of your personal data. Hence, Ayvens will before transferring your personal data outside Europe make sure to implement a Binding Corporate Rules (BCR) or a Standard Contractual Clauses (SCC). However, certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. These countries are listed online at: https://commission.europa.eu/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

**9. Your rights ** In order to protect data subjects concerned by the processing of personal data, the GDPR has implemented rights. The rights in question are as follows:

Please note that at any time you have the right to lodge a complaint to the competent local supervisory authority, the National Supervisory Authority for Personal Data Processing (ANSPDCP) at https://www.dataprotection.ro/.

If you wish to exercise the rights listed above, you will find the privacy policy of each Ayvens in their respective corporate websites:

Country + URL • Algeria - www.aldautomotive.dz • Austria - www.aldautomotive.at • Belarus - www.aldautomotive.by • Belgium - www.aldautomotive.be • Brazil - www.aldautomotive.com.br • Bulgaria - www.aldautomotive.bg • Chile - www.aldautomotive.cl • Colombia - www.aldautomotive.co • Croatia - www.aldautomotive.hr • Czech Republic - www.aldautomotive.cz • Denmark - www.aldautomotive.dk • Estonia - www.aldautomotive.ee • Finland - www.aldautomotive.fi • France - www.aldautomotive.fr • Germany - www.aldautomotive.de • Greece - www.aldautomotive.gr • Holding - www.aldautomotive.com • Hungary - www.aldautomotive.hu • India - www.aldautomotive.in • Italy - www.aldautomotive.it • Kazakhstan - www.aldautomotive.kz • Latvia - www.aldautomotive.lv • Lithuania - www.aldautomotive.lt • Luxembourg - www.aldautomotive.lu • Mexico - www.aldautomotive.com.mx • Morocco - www.aldautomotive.ma • Netherlands - www.aldautomotive.nl • Peru - www.aldautomotive.pe • Poland - www.aldautomotive.pl • Romania - www.aldautomotive.ro • Russia - www.aldautomotive.ru • Serbia - www.aldautomotive.rs • Slovakia - www.aldautomotive.sk • Slovenia - www.aldautomotive.si • Spain - www.aldautomotive.es • Sweden - www.aldautomotive.se • Switzerland - www.aldautomotive.ch • Turkey - www.aldautomotive.com.tr • Ukraine - www.aldautomotive.ua • United Kingdom - www.aldautomotive.co.uk

10. Security and data storage

We protect your data through technical and organizational security measures (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

Only those teams and employees who need to know your information within our company can access it. We make sure to implement administration rights and policies within our company, and we take all measures to ensure that employees, advisers and service providers keep your files confidential.

11. Cookies policy and websites

We may collect data via cookies to improve the user's browsing experience. Cookies are used, among other tracers, to store preferences and settings in order to save time, enable login, combat fraud, analyze the performance of the website and the services provided by the renter, and compile visit statistics.

For more details you can consult our Cookie policy by following this link: https://www.ayvens.com/en-ro/privacy-statement-ald/

12. Updates of this Privacy Policy

We may modify this Privacy Policy periodically to be compliant with any new regulations, so please review it regularly. If we change this Privacy Policy, we shall notify you by means of providing a notice on our website homepage. This Notice was last amended on 21.10.2024 .

13. How to contact us

To exercise the rights set out in the section 10 at any time, please send us a letter to the following address Bucharest, 1st District, 169A Calea Floreasca, Floreasca Business Park, Building A, 2nd Floor, Romania or contact our Data Protection Officer by e-mail at gdpr.ro@ayvens.ro and we will handle your request.