The purpose of this document is to inform you of the rules that will govern the processing of the personal data that the User provides through the portal located at the domain www.highmotor.com, owned by the company KYALAMI DIGITAL BUSINESS SL.

Using the website makes you a user of it and implies acceptance of all the conditions included in this Legal Notice. The user agrees to read this Legal Notice carefully each time they intend to use our website, as the website and its terms of use set out in this Legal Notice may be subject to change.

Identifying information

In compliance with the duty to provide information set out in Article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, the following details are provided:

The owner of this website is:

• Company name: KYALAMI DIGITAL BUSINESS SL
• Tax ID (CIF): B87733945
• Address: C/ José Echegaray, 8 Edif. 3 planta 2 Oficina 10, CP 28232 Las Rozas de Madrid, Madrid, Spain
• Email: [email protected]

HIGHMOTOR’s purpose

The purpose of DRIVINGECO is to offer official, complete and accurate information on cars sold in Spain, to showcase the best deals, and to send up-to-date and commercial information. We do not sell cars directly, but we provide the most complete information, sourced from the DGT, ANFAC and ANIACAM for sales data, and from official brands and dealerships for the prices and offers shown on the website.

Although the information is always kept up to date, last-minute changes beyond our control may occur, so we advise you to check the final price for your chosen configuration and specific situation with our partners, who will always be official sales channels in each case.

Confidentiality

HIGHMOTOR undertakes to comply with its obligation of secrecy regarding the personal data provided by Users and to process it in accordance with the current legislation on personal data protection. It has adopted the legally required levels of security for the protection of personal data and will take the necessary measures to prevent its alteration, loss, processing or unauthorised access, always taking into account the state of technology.

Data security

HIGHMOTOR guarantees the adoption of appropriate measures to ensure the confidential processing of such data. To this end, it has implemented all the necessary technical and organisational security measures to guarantee the integrity, confidentiality and availability of the personal data provided by the user, in particular those stipulated in Regulation (EU) 2016/679 (General Data Protection Regulation) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights.

Protection of personal data

The personal contact details you voluntarily provide to us will be treated confidentially, under the protection and specifications contained in Regulation (EU) 2016/679 (General Data Protection Regulation) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights. They will be recorded in the files “CONTACTS” and/or “CUSTOMERS FOR VEHICLE COMMERCIAL OFFERS”, duly registered with the Data Protection Agency, whose controller is KYALAMI DIGITAL BUSINESS S.L., depending on the specific purpose of the processing, namely sending information, responding to enquiries and general contacts via email, and sending a possible Newsletter with information, promotions and news about our activities that may be of interest to you.

The data subject may exercise their rights of access, rectification, erasure and objection by writing by ordinary post to the controller of the file at Calle José Echegaray, 8 Edif. 3 planta 2 Oficina 10, C.P. 28232 Las Rozas de Madrid, or by email to [email protected] with the reference “Data Protection”, through a signed written request for this purpose and attaching a copy of your ID card (DNI).

Purposes of data processing

We process the personal data you provide for the following purposes:

1. To comply with the duty to inform and obtain the consents required by the new European personal data protection regulation (GDPR).
2. Communications between the company and its customers/suppliers and the management arising from the services or orders contracted and/or carried out.
3. Sending advertising

What data do we process?

Within the framework of the services offered by the entity, and subject to the purposes you have consented to, our entity will only process the data strictly necessary for the proper management of the contractual relationship and/or the provision of services, and will exclusively be the data you have provided to us.

How long will we process your data?

The personal data you provide to us will be kept for as long as the current contractual/commercial relationship is maintained, or for a period of four years from the last business relationship, in accordance with tax regulations.

However, our entity will continue to retain your information to send commercial communications that we consider to be of interest to you, unless the data subject requests its deletion.

You may always exercise the rights recognised by current regulations by contacting us through the channel most convenient for you.

What is the legal basis for processing your data?

The legal basis for processing your data is the performance of the service contract necessary for carrying out the business transaction, or this legitimacy is granted by your express consent as the data subject concerned.

To which recipients will your data be disclosed?

The data you provide when requesting an offer authorises us to pass it on to our PARTNERS, so that they can contact you.

Accordingly, and giving effect to the above text, the data you have provided when requesting an offer for a model of the brand(s): , expressly authorises us to transfer your personal data to:

• ADSPOT MEDIA SOLUCIONES PUBLICITARIAS S.L., tax ID B-84424084, with registered postal address at calle José Echegaray, 8 Edif. 3 planta 2 Oficina 10, Las Rozas de Madrid (28232), registered in the Commercial Register. Email address: [email protected]. Legal Notice.

Likewise, the data you provide to us may be transferred to third parties in the automotive sector linked to financing and insurance, in order to offer you commercial and complementary alternatives to your request.

Your data will not be disclosed to any other third party, except where required by applicable law. Should this possibility change, you will be duly informed and your consent will be requested for such transfer. We also inform you that no international transfers will be carried out.

The User is informed that, for the proper provision of services (such as web hosting, support, email marketing, etc.), various service providers contracted by our entity (data processors) may have access to the personal information necessary to perform their functions.

These services provided by third parties are necessary for the development of our activity and, at all times, the processing of data they carry out is governed by a contract binding the processor to our entity. Under no circumstances will they use the information for other purposes, and they will process it in accordance with the guidelines stipulated by our entity, in line with its privacy policy and current data protection regulations.

Our entity, in its commitment to the privacy and data protection of the User, will only choose service providers that offer sufficient guarantees to implement appropriate technical and organisational measures, so that processing complies with applicable data protection legislation and guarantees the protection of the User’s rights.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation as to whether or not we are processing personal data concerning them. In this regard, you have the right to request:

• Access. The data subject shall have the right to obtain from the controller confirmation as to whether or not data concerning them are being processed, as well as detailed information about certain aspects of the processing being carried out.
• Rectification. The data subject shall have the right to obtain the rectification of inaccurate personal data concerning them, or to have incomplete data completed.
• Erasure. The data subject shall have the right to request the erasure of their personal data; in any case, erasure is subject to the limits established by the governing regulation.
• Restriction of processing. – The data subject shall have the right to request the restriction of the processing of their personal data.
• Objection to processing. – In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. The entity will stop processing the data, except for legitimate and compelling reasons, or for the exercise or defence of possible claims.
• Right to data portability. – That is, you shall have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format, and to transmit them to another controller. You may exercise these rights by contacting the controller. To do so, you may use the contact details provided at the beginning of this document. If you wish to obtain additional information regarding the exercise of your rights, you may also contact the Spanish Data Protection Agency. We also inform you that, if you consider it appropriate, you have the right to withdraw, at any time, the consent given for a specific purpose, without affecting the lawfulness of processing based on consent before its withdrawal. If you believe your rights have not been properly addressed, you may lodge a complaint with the Spanish Data Protection Agency. C/ Jorge Juan, 6. 28001 – Madrid. www.agpd.es.

LSSICE

In compliance with Article 21 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE), you are informed that by providing your data, you expressly authorise HIGHMOTOR to send you information by email or similar electronic means, in order to keep our users informed at all times of promotional offers on the topics you have requested information about, or other similar topics that may be of interest to you.

COMMUNICATIONS

For the purposes of any notifications in connection with this contract, HIGHMOTOR expressly designates as its address the one shown in this text, and you expressly designate as your address the one shown in the order request form.

To complete the purchase, you agree to keep the email address provided for communications with HIGHMOTOR operative, active and up to date, as it constitutes the preferred (though not the only) means of communication. In general, you undertake to keep your personal and contact details permanently up to date, and to notify any change in a verifiable manner.

Failure to provide such notification will mean that notifications sent to those addresses will be considered valid.