information on the protection of your personal data

A.1. Why does this Policy contain terms in capital letters?

Terms in capital letters are defined in Section 8 below (see Section 8 -USEFUL DEFINITIONS).

A.2. To whom does this Policy apply?

This Policy applies to customers (hereinafter referred to as “you” and related forms “your”) whose personal data is processed by Renault s.a.s., the parent company of Renault Group, located in France at 122, 122 bis avenue du Général Leclerc - 92100 Boulogne-Billancourt CEDEX (hereinafter “Renault”, “we”, “us”, and related forms “our”).

A “customer” within the meaning of this Policy is:

(i) the natural person who contacts us in order to obtain information on the products and services that we offer and/or a person who has interacted with us to express an interest in Renault Group products and/or services, and who has agreed to be contacted for this purpose by Renault;

(ii) the non-professional customer who has purchased, for private use, a vehicle of the Renault Group brands, namely Renault, Dacia, Alpine and Mobilize Beyond Automotive and, in Korea, Renault Samsung Motors (hereinafter the “Vehicle”);

(iii) the non-professional customer who has purchased products (e.g. accessories, etc.) and/or services, including those associated with a Vehicle (e.g. Connected Services, etc.).

Please also note that the Products and Services we offer are intended primarily for adults and, where applicable, for minors represented by their legal representatives; however, as our services are not specifically intended for minors, the processing of their personal data is only occasional.

A.3. Which products and services are covered by this Policy?

In order to meet its customers’ needs throughout their motoring lives, Renault has expanded its core business from being a manufacturer of Vehicles and a supplier of repair parts and other accessories to that of a service provider, in particular services associated with Vehicles.

Renault activities that may give rise to the processing of personal data described in this Policy are as follows:

• Managing customers’ account or user profile, enabling them to make full use of the Connected Services associated with their vehicle (My Dacia);
• Providing Connected Services offering driver assistance (such as anticipation messages) and navigation support for an improved driving experience;
• Your interaction with the websites published by Renault.

A.4. Which entities do we mean by the expression “Renault Group”?

Renault Group is composed of companies operating in France and/or abroad, each with a specific field of activity, for example:

(i) organising the distribution of Vehicles and Services in the countries where Renault Group is established and/or creating and developing new services, or marketing charging stations and associated services under the brand “Mobilize Power Solution” (hereinafter the “Renault Sales Subsidiaries”);

(ii) providing financial products under the brand “Mobilize Financial Services”, such as long-term lease offers, lease purchase offers, insurance offers, etc. (hereinafter the “Renault Financial Subsidiaries”); and

(iii) as an automotive manufacturer, defining the distribution strategy for Vehicles and/or Services. 

A.5. How does Renault organise the distribution of its Vehicles and/or Services?

To organise the distribution of Vehicles and/or Services in the various geographical territories where Renault Group is established, Renault s.a.s. relies on:

• The Renault Sales Subsidiaries. The Renault Sales Subsidiaries responsible for organising the distribution of Vehicles and Services are contractually bound, respectively, by a partnership agreement (or, where applicable, an agency agreement or authorised repairer agreement) to their Primary Network, which ensures territorial coverage by establishing physical premises such as dealerships, agencies or garages (to find a location, please consult our website: www.dacia.co.uk/find-a-dealer. The Secondary Network is composed of companies independent from Renault Group, contractually linked to the Primary Network. Together, the Primary and Secondary Networks constitute the Renault Group authorised network (hereinafter the “Renault Commercial Network”).
• The Independent Commercial Network. It is composed of companies that do not belong to Renault Group (identified by an asterisk in the list available here on our website: www.dacia.co.uk/find-a-dealer, but with which we have entered into exclusive distribution agreements regarding Renault Vehicles and/or Services (such as repairs, maintenance services and safety) in their geographical area of competence.
  
  

Therefore, depending on the country in which you are located, you may purchase Vehicles, Products and/or Services either from the Renault Commercial Network or from the Independent Commercial Network, which are together referred to in this Policy as the “Renault Distribution Network”

B.1. The purpose of this Policy

The purpose of this Policy is to enable our customers to understand, in a clear, concise and accessible manner, how their personal data is used, the commitments and measures we implement to ensure the protection of their personal data, the rights they have and how to exercise them.

To learn more about Renault Group’s commitments regarding personal data, please click here to consult our website: www.renaultgroup.com/en/renault-group-and-your-personal-data/

This Policy may, where appropriate, be supplemented by other notices relating to the protection of personal data.

B.2. Which processing activities does this Policy apply to?

Processing activities not covered by this Policy

This Policy does not apply to processing activities:

• carried out in relation to data of professional customers who have purchased Vehicles for resale as part of a commercial activity and/or for professional use;
• carried out in relation to job applicants (Renault Group’s policy is available here: https://www.renaultgroup.com/talent-your-personal-data/);
• carried out by Renault, the parent company of Renault Group, in relation to the data of employees and/or collaborators, in particular those of the Renault Distribution Network;
• carried out jointly by Renault with, respectively, the Renault Sales Subsidiaries. You can review the processing activities we carry out jointly with the Renault Sales Subsidiaries by visiting their respective websites (see the directory available here: www.dacia.co.uk/find-a-dealer);
• carried out as independent data controllers by (i) the Renault Distribution Network, (ii) the Renault Sales Subsidiaries and (iii) third parties outside Renault Group.
  
  

Processing activities covered by this Policy

Within the framework of this Policy, we present to you the personal data processing activities carried out by Renault in connection with your use of the Dacia Travel Companion App, acting as a data controller independently from our affiliated companies (Renault Sales Subsidiaries, Renault Financial Subsidiaries, etc.). 

For the purposes of this document, “Renault”, “we”, “us” and related forms refer to Renault s.a.s. acting as data controller within the meaning of the applicable personal data regulations.

Renault s.a.s. is located in France, at 122-122 bis avenue du Général Leclerc – 92100 Boulogne-Billancourt – France. The contact details of its Data Protection Officer are as follows: Renault s.a.s., Data Protection Officer, API: FR BLN CRI 1BW, 122-122 bis avenue du Général Leclerc – 92100 Boulogne Billancourt – France, and dataprotection-com@renault.com.

As a general rule, we undertake to collect only personal data that is relevant and appropriate for each of the purposes for which we process it (see Section 3 - WHY IS YOUR PERSONAL DATA USED?).

In this section, we explain the context in which your data is collected and the categories of data we collect.

Collection from you, as a user of the Dacia Travel Companion Application

We collect your personal data in particular when:

• you create a user profile to access the Dacia Travel Companion application;
• you agree to the use of the location function and the front-facing camera of your smartphone in order to benefit from the features offered by the app.  

The personal data we collect depends on our interaction with you and may include information relating to:

• your contact details (surname, first name, email address);
• Vehicle identification data (VIN);
• data related to the use of the connected Vehicle you are driving (mileage, planned route) and the provision of Connected Services or embedded applications;
• subject to your consent where required by applicable regulations, your geolocation data (to suggest suitable places for breaks during your journey);
• subject to your consent where required by applicable regulations, your “lifestyle” data (sleep time before a journey);
• if you authorise the App’s features to use the smartphone’s front-facing camera, the collection of your facial template enabling the detection of signs of drowsiness from your face.
  
  

In all cases, we invite you to keep us regularly informed in writing of any changes concerning your personal data

We provide you with explanations on the context of collection of your data, the purposes for which we process it, as an independent data controller, and the period for which we retain it.

Renault only has access to your data in connection with the management of your account and to data collected anonymously as part of improving our application. This data is stored on Renault servers.

The other data is stored only on your telephone.

5.1 - Your rights

You have several rights under the regulations relating to the protection of personal data:

• A right to object to the processing of your personal data, subject to demonstrating reasons relating to your particular situation, and a right to request the restriction of the processing of your personal data in certain cases provided for by the regulations. Where applicable, we will no longer process this personal data unless we have compelling legitimate grounds to do so that override your interests, rights and freedoms, or if such processing is necessary for the establishment, exercise or defence of legal claims.
• A right to withdraw your consent at any time for the purposes for which we collected your consent.
• A right to information: you have the right to receive clear, transparent and understandable information on how we use your personal data and on your rights. This Policy is an example of this.
• A right of access to your personal data: you have the right to obtain information concerning the processing of your personal data (in particular the data that is used, all information available as to the source of the data when you have not provided your personal data directly to us, the purposes for which we use it, the recipients and/or categories of recipients to whom your personal data has been disclosed, the retention period applied to your personal data, etc.) as well as a copy of it.
• A right to rectification: you have the right to have your data corrected if it is inaccurate or incomplete, despite our efforts to keep it up to date, which will enable us to comply with our obligation to hold up-todate data concerning you.
• A right to data portability, that is to say, under certain conditions, the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and to have it transmitted to a third party where technically feasible.
• A right to erasure (or right to be forgotten): you have the right to have your data erased or deleted. This right may be limited in view of our contractual obligations (ongoing contract) or legal obligations (in particular the prevention of legal actions).
• A right to restriction: you have the right to exercise this right if (i) you wish to contest the accuracy of your personal data, or (ii) you need the data processed by Renault in order to exercise or defend your rights in court and wish to prevent any possible deletion by Renault (for example, where the legal retention period has been reached and Renault no longer has an operational need to retain this data, etc.). Please note that you benefit by default from this right when you have objected to processing based on Renault’s legitimate interest by demonstrating reasons relating to your particular situation, while we verify whether the legitimate grounds on which we base this processing override your interests, rights or freedoms.
• Where applicable, a right to define instructions, either general or specific, in relation to certain processing activities, for the retention, deletion and communication of your personal data in the event of death. You may amend or withdraw these instructions at any time. You may communicate these specific instructions to us by writing to the address mentioned below.
• Lastly, you have the right to lodge a complaint with the competent supervisory authority in your country regarding the protection of personal data. We encourage you to contact us before lodging any complaint so that we can try to resolve your issue together.

5.2 - How can you exercise them?

As part of processing activities carried out on data collected during the registration of your vehicle test, Renault does not have access to your data; it is not stored on our servers and is deleted at the end of the test.

To exercise any of your rights regarding other processing activities carried out by Renault on data collected during your interactions with Renault, you may your request at any time by using our form , or calling our customer relations team on 0344 335 1111 or by post to: Renault UK, The Rivers Office Park, Denham Way, Maple Cross, Rickmansworth WD3 9YS. We may request certain information or documents (identity document, vehicle registration document) when we fail to identify you or to identify your vehicle data.

Where necessary, your personal data is stored on secure servers. We implement, and require our processors and third-party partners to implement, appropriate security and data protection measures in line with the latest technologies.

Where the processing of personal data involves a transfer, we ensure that such transfer is carried out under appropriate conditions guaranteeing a sufficient level of protection, security and confidentiality.

As part of the creation of a digital account, entering a password that complies with our security standards is mandatory and forms part of our privacy policy. It is your responsibility to keep it secret.

Where possible, your data is processed within the European Economic Area (EEA). However, as some of our service providers or their subcontractors are located in countries outside the EEA, your personal data is processed in those countries. Some of these countries may have personal data regulations that differ from those of the European Union. In such cases, we pay particular attention to ensuring that the transfer is carried out in compliance with the applicable regulations and we implement safeguards ensuring a level of protection of your privacy and your fundamental rights equivalent to that offered by the European Union (in particular through the use of the European Commission’s Standard Contractual Clauses). Upon simple request sent to the address mentioned in the section “WHAT ARE YOUR RIGHTS”, we can provide you with further information on these transfers (including the European Commission’s standard contractual clauses). 

We may occasionally amend this notice. Where necessary or required, we will inform you and/or seek your agreement.

We therefore invite you to review it each time you visit in order to become acquainted with its latest version.

This version provides information relating to the processing of your personal data for Connected Services and embedded applications and informs you about the recipients of your personal data, within and/or outside Renault Group. 

"Joint controller" or "co-controller": these two expressions are synonymous. Whenever we indicate that we act as a joint controller jointly alongside one or more other legal entities, this means that we jointly determine with them how and why your personal data is used, either through a common decision or through separate but convergent decisions.

“Personal Data” means any information about you that, either alone or in combination with other information, identifies you directly (such as your name) or indirectly (such as by reference to a unique customer number or your Vehicle’s unique identification number).

"Renault Subsidiary": means the affiliated companies of RENAULT s.a.s., i.e. the legal entities controlled by RENAULT s.a.s. or under its direct or indirect control. "Control" means the power to direct the management or policies of such affiliated companies, either directly or indirectly and whether through ownership of voting securities or otherwise.

"Renault Sales Subsidiaries": means the Renault Subsidiaries in charge of distributing Vehicles and Products and/or Services in the countries where the Renault Group operates.

“Products and/or Services” means, individually or in combination, the Vehicle, the Vehicle’s accessories, and any warranty or Connected Services contracts associated with your Vehicle. 

“Renault Distribution Network” means both the Renault Sales Subsidiaries and the Independent Sales Network.

"Independent Sales Network": means the legal entities not affiliated with RENAULT s.a.s. with which RENAULT s.a.s. has entered into exclusive distribution agreements for Vehicles, Products and/or Services within a specific geographical area.

"Primary Network": means the dealerships, agencies or garages contractually bound to the Renault Sales Subsidiaries through a partnership agreement.

"Secondary Network": means independent companies not belonging to the Renault Group, contractually bound to the Primary Network, most often through an agency, distribution or authorised repairer agreement. In this Policy, “Controller” means RENAULT s.a.s., the parent company of the Renault Group, which alone or jointly with others determines the purposes and means of the processing described in this document.

"Processor": means any natural or legal person, public authority, agency or other body which processes personal data on behalf of and under the instructions of the Controller. As part of this policy, we remind
you of the categories of activities involving the processing of personal data that we entrust to processors (see Section 4.2 above for more information).

"Connected Services": means paid or free intangible features made available to Vehicle owners or users, enhancing the driving experience, the relationship and the quality of service, through connectivity embedded in the Vehicle. This connectivity relies on the connection of the Vehicle to an external ecosystem operated by RENAULT S.A.S. and/or a Third Party. Connected Services are used in the Vehicle or via an application on a smartphone or tablet interacting with the Vehicle. In addition, certain Connected Services enable the Vehicle owner to access features provided by the manufacturer RENAULT s.a.s. or by Third Parties, the main purpose of which is to ensure the proper functioning of the Vehicle throughout its life cycle.

"Third Parties": means, in a generic sense, entities that are not Renault Subsidiaries, such as business partners or our Sales Network.

"Authorised Third Parties": means certain authorities that have the power to require organisations to disclose documents or information that may include personal data.

"Processing: means any operation or any set of operations, carried out with or without automated means, applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, extraction, consultation, use, disclosure by transfer, dissemination or any other form of making available, matching or interconnection, restriction, erasure or destruction.

"Vehicle": means the vehicle(s) of the Renault Group brands.