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Privacy policy

Privacy policy

Alphabet Polska Data Protection Information

The expectations of our potential and present clients as well as other users of vehicles covered by our agreements as to the high standard of our services are the main benchmark for our activities aimed at establishing and maintaining long-term business relationships. One of the major aspects of such relationships is the privacy and integrity of personal data processed by our company. The purpose of this “Privacy  Privacy” is to describe steps taken by our company to ensure compliance with the applicable personal data protection law.

Changes to our Data Protection Notice

Alphabet may modify or update this Notice when necessary, to reflect customer feedback and changes in our Alphabet Products and Service. Please review it regularly. When we update this Notice, we will revise the 'Last Update' date at the top of the Notice. If there are material changes to the Notice or in how Alphabet Polska uses your personal data, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Notice to learn more how Alphabet Polska is using and protecting your information.

The Alphabet Polska (Alphabet) data protection information describes in the following sections how we collect, process and use personal data of our customers and potential customers.

Last update: 14 November 2018

Who is responsible for personal data processing?

The controller of your personal data provided in connection with the cooperation with our company, including but not limited to the use of the vehicle covered by our services, use of our websites, or the data provided in the form available on the said websites is Alphabet Polska Fleet Management Sp. z o.o., with its registered office at ul. Wołoska 22a, 02-675 Warsaw (Alphabet Polska). 

With your consent, your personal data can be forwarded to BMW Vertriebs GmbH sp. z o.o. Oddział w Polsce, with its registered office in Warsaw (02-675), ul. Wołoska 22A, BMW AG, with its registered office in Munich, Petuelring 130, Germany that will, consequently, act as the controller of your personal data used for marketing purposes. 

By clicking the links placed on the Alphabet Polska website, you can be redirected to websites or services that are part of a service provided by entities other than Alphabet Polska and, by the same token, are beyond Alphabet Polska’s indirect or direct control, where processing, including collection, of personal data is carried out in accordance with the rules set by such entities, for instance, in the privacy policy applicable to such services or applications. 

What personal data is processed and collected by Alphabet Polska?

Alphabet Polska processes the following data referring to you:

  • data provided by you in the form available on our website, the damage reporting form or in response to our direct marketing activities or our service satisfaction surveys, i.e. full name, company name, position held, e-mail address, phone number, vehicle registration number, details of driving licence(-s), details of damage event, opinion on our services, content of claim or inquiry and details obtained from you in pursuit of your claim or inquiry;
  • data obtained from third parties such as the insurance company that provides information about the method or scope of damage claim adjustment, the provider of the vehicle giving details of where and when the vehicle will be provided, our partner who provides a service for the vehicle used under an agreement executed with our company, the car body shop handling the repair of the vehicle after it has been damaged. These entities provide us with the following data: full name, company name, position held, e-mail address, phone number, vehicle registration number, damage caused and repair made, where and when the vehicle is to be collected, information contained in the inquiry or claim. 
Where does the personal data processed by Alphabet Polska come from?

Alphabet Polska processes personal data provided directly by you, your employer in connection with the performance of the lease agreement (or any other agreement between us) or a claim adjustment procedure followed for a vehicle covered by an agreement as well as the data provided by third parties such as vehicle importers and distributors, car garages, insurance companies to the extent set out in item II above.

How does Alphabet Polska process your data?

Your personal data will be processed for communication purposes in connection with a request for quotation, complaint, question related to the current services provided for vehicles covered by agreements executed with our company, inquiries about an authorisation to go abroad, questions about the vehicle delivery or collection, claim report being sent, for the purpose of responding to inquiries and requests sent, vehicle user satisfaction surveys, performing the agreement between you and Alphabet Polska, for marketing Alphabet Polska’s own products and services (specifically, to carry out direct marketing activities, by mail, e-mail and phone [provided that you have given us the relevant consents to your e-mail address or phone number being used) and for the purposes of analysis, statistics, archiving, settlement of duties performed in connection with personal data processing, pursuing or defending claims, based on a legitimate interest or, where necessary, the consent given.

Alphabet Polska also uses the Google Analytics service provided by Google Inc. Google Analytics uses cookies, which are text files installed on your hard disk, to analyse how the users are using the website. Information generated by such cookies (e.g. the IP address) is collected and stored by Google on its servers located in the USA to assess the form of using the website (it is legally permitted for such data to be transferred to the USA as a result of Google having entered into the EU-USA Privacy Shield agreement). This data is used to draw up activity reports for the website administrators.

Google may also forward information collected through cookies to other entities if it is legally required to do so or such entities process the data for Google. Google does not match your IP address with any other data held. 8.

For more information about personal data being processed in connection with cookies and similar measures applied by Alphabet Polska, please refer to the Cookie Policy.

Alphabet Polska requests you to provide your data only to the extent necessary for you to contact Alphabet Polska and present your inquiry or request or execute and perform an agreement. If you do not provide us with your data necessary to contact you, Alphabet Polska will not be able to follow your request or demand. Otherwise the data is provided voluntarily.

Who does Alphabet Polska forward your data to?

Alphabet Polska can provide your personal data to entities carrying out their own tasks or tasks related to the performance of agreements executed by Alphabet Polska, i.e. car garages, companies running deposit sites, logistics companies, insurance companies, insurance agents, IT service providers, marketing service providers and car dealers cooperating with Alphabet Polska that Alphabet Polska uses to perform agreements, under separate written agreements, as well as the BMW Group entities for internal administrative purposes of the BMW Group.  In any case, Alphabet Polska provides data to third parties only when they a legal ground to process the same, e.g. to have vehicles insured with a given insurance company.

Alphabet Polska can also forward your data to entities performing public tasks (to the extent they are actually carrying out such tasks) if this is required under the applicable law. 

Having obtained your consent, Alphabet Polska can also provide your personal data to the BMW Group entities for their marketing purposes, including the presentation of products and services offered by such entities.

What rights do you have in connection with your data being processed by Alphabet Polska?

You have the right of access, right to rectification, right to erasure, right to restriction of processing, right to obtain and have the data provided by you transferred to another controller as well as the right to object against your data being processed. If the processing is based on your consent, you can withdraw it at any time. 

You can exercise these rights when:

  • for the right to rectification: the data is incorrect or incomplete;
  • for the right to erasure: the data is no longer needed for the purposes for which it was collected by Alphabet Polska; you have withdrawn your consent to your data being processed; you have first objected to such data being processed; the data is processed illegally; the data should be deleted to meet a legal obligation;
  • for the right to restriction of processing: the data is incorrect – for a period enabling Alphabet Polska to verify the accuracy of the personal data; the data is processed illegally but you will not want it to be deleted; your data is no longer needed by Alphabet Polska but can be used by you to defend or pursue claims; or you object to the data being processed – pending the verification whether the legitimate grounds of the controller override those of the objection made;
  • for the right of portability: data is processed based on your consent or an agreement executed with you and is automated.

Where your data is being processed, you have the right to file a complaint with the supervisory authority, which is the President of Personal Data Protection Authority.

What is the retention period for your data?

Your personal data will be processed as long as there is a legal relationship between you or your employer and Alphabet Polska. Following the termination of this relationship, Alphabet Polska will process your personal data as long as it is permitted to do so under the applicable law, especially under the regulations imposing obligations to retain tax and accounting documents and the statute of limitations, for a maximum term of 20 years when claims are pursued or defended in connection with damage caused as a result of a tort/delict and for 5 years following the completion of the complaint procedure. In case of requests for quotation addressed to Alphabet Polska which which do not result in the execution of an agreement, the data will be processed for 3 months, counted from the date of the last contact. 

How does Alphabet Polska protect your data?

Alphabet Polska uses various tools to safeguard your personal data such as encryption or state-of-the-art verification tools to protect data and its integrity and keep it safe and accessible.  

We cannot guarantee 100% protection against unauthorised access in case of data transfers via Internet and within the website but we can ensure that our company, our partners and service providers make the best efforts to protect your personal data in line with the applicable data protection law, by the state-of-the-art physical and electronic means as well as other security measures for data processing. We use, inter alia:

  • authorisation of access to your data under the need-to-know principle;
  • an IT firewall protection system to ensure protection against unauthorised access, by e.g. hackers;
  • constant monitoring of access to IT systems to detect and prevent the misuse of personal data.

If you have obtained a password from us and have been given access to certain areas of our website or other portals, applications or services provided by us, you are responsible to keep your password secret and ensure that it is consistent with all security procedures notified to you by our company. Specifically, we request that you do not forward your password to third parties.

How can you contact Alphabet Polska?

In order to exercise the rights vested in you under the present notice, including the right to withdraw consents to your personal data being processed, and in any other matters related to personal data processing, please contact Alphabet Polska under the phone number: 22 820-55-55 or e-mail address: kontakt@alphabet.pl or contact the data protection officer Malwina Wasilewska under the number: 22 820 56 01 or the e-mail address: daneosobowe@alphabet.pl