PRIVACY POLICY

PORTAL AUTOACTION

As an integral part of the AUTOACTION PORTAL Terms of Use and Conditions of Use, this document, called the Privacy Policy, has the purpose of establishing the rules on obtaining, using and storing the data and information collected from USERS, as well as registering their activities .

1. Obtaining the data and information:

1.1. The data and information will be obtained when the USERS interact with the various functionalities existing in AUTOACTION PORTAL, providing the information voluntarily, such as in creating an account or sending a contact email, for example.

2. Data and Information Storage:

2.1. All data and information collected from USERS will be incorporated into the AUTOACTION PORTAL database, owned by AUTO ACTION USA LLC, NIPC 514 779 357, headquartered in Lagoas Park, Edifício 7, Piso 1, 2740-244 Porto Salvo.

2.2. The data and information collected will be stored in a safe environment, observing the state of the art available, and can only be accessed by people qualified and authorized by AUTOACTION.

2.3. AUTOACTION can use cloud computing to store USER data, especially to allow its processing in other countries, always safeguarding the confidentiality and integrity of the data retained, in accordance with the law in force.

2.3.1. Currently, AUTOACTION maintains the data collected through its AUTOACTION PORTAL on servers located in data centers located in the European Union.

2.4. Since no security system is absolutely secure, AUTOACTION and any of the companies that make up its corporate group are exempt from any liability for any damages and / or losses resulting from failures, viruses or invasions of the AUTOACTION PORTAL database, except in cases of fraud or guilty of any of these companies.

3. Use of Data and Information:

3.1. The data and information collected may be used for the following purposes:

1. To respond to any doubts and requests of the USERS;

2. Compliance with legal obligations or court orders;

3. Constitute, defend or regularly exercise rights in a judicial or administrative context;

4. To prepare general statistics, based on vehicle data, to identify the profile of USERS for the development of campaigns of AUTOACTION or any companies that compose their corporate group, and there is no processing of personal data of the USERS for this purpose. Third parties may register the information, treatment or grouping of said data;

5. Develop the database of USERS for the purpose of personalization of services, better service of these and development of new features of AUTOACTION PORTAL;

6. Guarantee the safety of USERS;

7. Keep the personal data of the USERS updated for the purpose of contact by telephone, electronic mail, SMS, mail or other means of communication;

8. Inform the USERS about news and events of AUTOACTION or any of the companies that make up their corporate group, according to their preferences to receive them.

3.2. The database formed by AUTOACTION through the collection of AUTOACTION PORTAL data will not be shared, sold, assigned, transferred, informed or rented for the benefit of third parties not belonging to its corporate group.

3.3. In order to use the database described above by the companies belonging to its corporate group, these will undertake to respect the terms of this Privacy Policy and the principles of necessity and relevance in relation to the objectives of AUTOACTION PORTAL, under penalty of fine and severe measures in case of noncompliance, such as to bear the losses that AUTOACTION will bear.

3.4. The acquired data can only be accessed by professionals duly authorized by AUTOACTION, respecting the necessity to which they will be submitted, the relevance for the objectives of these and the interests of the USERS, in addition to preserving their privacy.

3.5. If you wish to cancel your access account, the User may request the deletion of your data, and AUTOACTION may remain with the activity data record in AUTOACTION PORTAL and other legally required USER information, for a maximum period of five ), years for auditing and preservation of rights, with the possibility of definitively excluding them at their convenience in a shorter period.

3.5.1. The request for exclusion of data made by the USER will be answered after the deadline indicated in clause 3.5. During this time, even if stored for purposes of audit and preservation of evidence, they will no longer go through the assumptions of treatment detailed in clause 3.1.

3.6. In accordance with the legislation applicable to the Protection of Personal Data, the User benefits from the rights of access, rectification, opposition and limitation of the treatment, as well as, upon request to the entity responsible for the treatment, the rights to portability and elimination of data that tell respect. The User may also withdraw his consent when it is a condition of legitimacy for the processing of data made. To do so, please contact AUTOACTION at the following email address: soporte.pt@auto-action.com. You may also file complaints with the Legally Established Control Authority.

4. From the Register of Activities:

4.1. AUTOACTION will record all accesses made by USERS in the AUTOACTION PORTAL internet application, through logs, including:

1. USERS IP address;

2. Actions made by the USERS in the AUTOACTION PORTAL;

3. Pages accessed by USERS;

4. Dates and times of each action and access to each AUTOACTION PORTAL page;

5. Information about the device used, operating system version, browser, among other applications installed;

6. Session ID of USERS.

4.2. The registrations mentioned in item 4.1 may be used by AUTOACTION in cases of investigation of fraud or improper changes in their systems and data.

4.3. AUTOACTION applies security controls in relation to the records of access to the AUTOACTION PORTAL application that it stores, such as:

1. Restricted control of access to such data to a limited number of employees, whose permissions will be limited to the need for the functions they perform in AUTOACTION;

2. Double authentication factor for access to such data, such as the need for additional authentication of the manager or immediate superior of the AUTOACTION employee who wishes to access the data;

3. Registration of those who made access to a certain registry of access to the application, when and for how long;

4. Use of encryption, password and obfuscation of data at rest and encryption in the data in transit.

4.4. The records of access to the AUTOACTION PORTAL application shall be kept in an interoperable and structured format in order to facilitate the understanding of those who have access through a judicial order or legal determination, according to the law.

5. Cookies and other data collection technologies:

5.1. AUTOACTION PORTAL may make use of cookies, and it is up to USERS to configure their Internet browser, should you wish to block them. In this case, some features of AUTOACTION PORTAL may be limited.

5.2. AUTOACTION PORTAL also uses cookies to store the browsing behavior data of its USERS.

5.3. AUTOACTION PORTAL may also use web beacons to collect USER behavior data on AUTOACTION PORTAL pages, where the installation of files on the devices is not required.

5.4. Other technologies may be used to obtain browsing data from USERS, however, they will always respect the terms of this policy and their options regarding their collection and storage.

6. General Provisions:

6.1. The provisions of this Privacy Policy may be updated or modified at any time, and it is up to the USERS to verify it whenever they access the AUTOACTION PORTAL.

6.2. USERS should contact us in case of any doubt related to the provisions of this Privacy Policy through the "Contact Us" section of the AUTOACTION PORTAL.

7. Applicable Law and Jurisdiction

7.1. The Terms and Conditions of Use described herein shall be interpreted in the light of the Portuguese legislation in the Portuguese language, and the Lisbon District Court shall be elected to settle any dispute or controversy surrounding this document, unless there is a specific applicable legislation.

9. Glossary:

9.1. For the purposes of this document, the following definitions and descriptions should be considered for your best understanding:

1. AUTOACTION: The term used in this Privacy Policy to identify the holder and owner of this AutoAction Portugal Unipessoal Lda, NIPC 514 779 357, located in Lagoas Park, Edifício 7, Piso 1, 2740-244 Porto Salvo.

2. Cloud Computing: or cloud computing, is service virtualization technology built from the interconnection of more than one server through a common information network (eg the Internet), in order to increase the availability of services sustained.

3. Cookies: Files sent by the AUTOACTION PORTAL server to the USERS computer, in order to identify the device used and obtain access data, such as navigated pages or clicked links, thus allowing the user to customize the navigation according to the your profile.

4. IP: Abbreviation for Internet Protocol. It is a set of numbers that identifies the Internet access connection used by USERS to access the AUTOACTION PORTAL.

5. Logs or logs of the application: Logs of activities of the USERS made in the AUTOACTION PORTAL.

6. AUTOACTION PORTAL: Set of pages and features contained by the domains https://b2b.auto-action.com/ and subdomain hhttps: //adm-en.auto-action.com/.

7. Website: Name for web page.

8. USER: Who accesses the AUTOACTION PORTAL or who has an Access Account.

9. Web beacons: Lines of programming in HTML pages that have as purpose to obtain details of the navigation of the USER, the example of how long the site was left open, which address was visited next, among others.

Update: March 13, 2018.

AUTOACTION USA LLC