Basic information on data protection

Data Controllers

Depending on which MOT station (ITV) the vehicle performs the E-Reform, the data controller will be:

APPLUS ITEUVE TECHNOLOGY, S.L.U. (Applus Iteuve).
Registered Office: Parque Empresarial Las Mercedes, Calle Campezo Nº1, Edificio 3, 28022 Madrid.
T.I.N.: B.-81.041.444.

APPLUS ITEUVE EUSKADI, S.A. (Applus Euskadi).
Registered Office: Polg. Ugaldeguren I, Parc. 8. 48170 Zamudio (Vizcaya).
T.I.N.: A48551915.

ITEUVE CANARIAS, S.L.U. (Iteuve Canarias).
Registered Office: Camino de San Lázaro 166, Los Rodeos 38206, San Cristobal de La Laguna, Santa Cruz de Tenerife.
T.I.N. B-76.168.590

Hereinafter, all collectively “Applus+”

More information

Purposes

(a) Management of the “E-Reforma” platform.

(b) Cooperation with regulatory authorities and Law Enforcement Agencies.

(c) Management of your suggestions, inquiries and/or claims.

More information

Lawful basis

(a) Performance of a contract to which the data subject is a party.

(b) Compliance with current legal obligations to which Applus+ is subject.

(c) Legitimate interest.

More information

Personal Data

• Identification Details: name and surname, signature, and, in case of requesting an invoice, T.I.N. (N.I.F).
• Contact Details: Address, Town/City, Postal Code, Autonomous Community, email, contact telephone number and province.
• Service Payment Data: debit or credit card, bank accounts (in case of deferred billing).
• Others: vehicle license plate, chassis number (VIN).

In the case of corporate clients: names and surnames, telephone number and contact details of the representative or contact person in the company.

More information

Recipients

Applus Group companies and other service providers.

Law enforcement agencies, judges and courts, regulatory entities, government authorities or other competent third parties.

More information

Rights

Among others, the rights of access, rectification and erasure of personal data, the right to object to the processing of personal data and to revoke your consent.

The exercise of these rights can be made effective by sending an email to rgpd.automotive@applus.com

More information

Further information

We recommend that you read this information carefully.

1. What Personal Data do we collect?

1.1 Personal Data that you provide us directly

1.2 Personal Data that we collect from other sources

1.3 Personal Data that you provide us about third parties.

2. How and on what basis do we process your Personal Data?
3. What rights do you have over your Personal Data?
4. How do we share your Personal Data and with whom?
5. How do we protect your Personal Data?
6. For how long do we keep your Personal Data?
7. Contact Us
8. Changes to this Privacy Policy

This Privacy Policy describes the way in which Applus Iteuve, Applus Euskadi or Iteuve Canarias, as the case may be, depending on which MOT station the vehicle performs the E-Reform, hereinafter all together will be referred to as "Applus+" collects and processes your Personal Data, as well as the way in which we use and protect said information respectively, in addition to the rights you hold in relation to it.

Applus+ will collect and process personal data respectively in its capacity as Data Controller. You can contact Applus+ (“Us”) through the channels enabled and indicated in section 7 of this Policy.

This Privacy Policy applies to all personal data we collect about you in relation to the use of the "E-Reforma" Platform.

"Personal Data" means any information relating to an identified or identifiable natural person («the data subject»); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, cultural or social identity of that natural person.

1. What Personal Data do we collect?

We collect your Personal Data through various sources including information that you provide to us directly when contacting Us through the "E-Reforma" Platform.

Please note that we must collect certain personal data by legal mandate, or as a consequence of the contractual relationship we have entered into with you. Refusal to provide such information may prevent or delay compliance with such obligations. When collecting your personal data, we will inform you regarding the mandatory nature of providing said data, as well as the consequences of not doing so.

1.1 Personal Data that you provide us directly

The categories of Personal Data that we will collect directly from you include:

• Identification Details: Name(s) and Surname(s); signature, T.I.N. (for the issuance of invoices).
• Contact Details: Address, Town/City, Postal Code, Autonomous Community, telephone number; email and province.
• Service Payment Data: debit or credit card number; bank account number (in case of deferred billing).
• Other data such as: vehicle license plate; vehicle chassis number (VIN).
• In the case of corporate clients: name and surname; email; address and telephone number of representatives or contact persons.

1.2 Personal Data that we collect from other sources:

We collect Personal Data about you through the Directorate-General for Traffic (DGT): name and surname, ID number (DNI), chassis number, vehicle license plate, and information on the existence of compulsory insurance.

In the event that you have failed an inspection with another entity other than Applus+ and want to pass the second inspection at one of our stations, we will collect the data from your file from the other company to be able to provide the service.

In the event that you request a duplicate of the technical inspection card due to loss or any other cause, we will request the information contained in said card from the provincial traffic headquarters or the town hall of the place where the vehicle is registered.

1.3 Personal data that you provide us about third parties

When you provide Applus+ with personal data, such as contact information and/or vehicle license plate or any other data relating to third parties, you will be directly responsible for informing those persons about their rights and obtaining their explicit consent, when necessary, regarding the processing (including transfers) of their personal data, as deemed necessary and in accordance with relevant local data protection legislation, as established in this policy.

2. How and on what basis do we process your Personal Data?

We use and process the Personal Data we collect about you for the purposes and with the lawful bases indicated below:

(a) We will process your personal data in order to comply with our contractual relationship with you and thereby be able to manage the “E-Reforma” Platform, including within it the provision and management of the documentary processing of certain technical vehicle inspection services as well as the management of the documentation required by regulations in relation to said inspections and the accounting, fiscal and administrative management of the service, online payment of the service, as well as, if applicable, sending the invoice in electronic format by email.

(b) We will also process your Personal Data in order to guarantee an optimal level of compliance with respect to the current legal obligations to which Applus+ is subject, as well as to cooperate with regulatory authorities and law enforcement agencies when necessary, as provided in Section 4 of this Privacy Policy to communicate your personal data, as well as other complementary information, in response to requests issued by the competent authorities and/or entities, as provided in applicable legislation or by law enforcement agents in the exercise of their functions.

(c) We will process your personal data on the basis of our legitimate interest for the following purposes:

• To resolve your suggestions, inquiries or claims, given the legitimate interest that Applus+ holds in the sense of carrying out its business activity diligently and being able to attend to the requests of the interested parties;
• As mentioned in Section 4 of this Privacy Policy, among others, for communications to any of our employees, agents, business partners, or other companies of the Applus Group, who process Personal Data for the purposes described in this Privacy Policy, on the basis of the legitimate interest that Applus+ holds in the sense of carrying out its activity diligently;
• In order to allow third-party service providers and suppliers contracted by Us to access personal data to be able to provide us with the services necessary to fulfill the purposes described in this Privacy Policy;
• To resolve your suggestions, inquiries or claims;
• For any communication to third parties, as necessary as part of due diligence processes in the context of corporate restructuring operations to which we are a party, in line with the provisions of Section 4 (d) of this Privacy Policy;

When Applus+, as the case may be, processes Personal Data based on its legitimate interests, it will perform a balancing test in order to ensure that your interests or your fundamental rights and freedoms do not prevail over our legitimate interest.

3. What rights do you have over your Personal Data?

You have certain rights in relation to your Personal Data, without prejudice to the provisions of local legislation. These rights include:

• Knowing how we are processing your Personal Data and accessing those Personal Data that Applus+ or other companies in its group have about you, as the case may be;
• Requesting the rectification of inaccurate or incomplete Personal Data;
• Requesting the erasure of your Personal Data when they are no longer necessary for the purposes for which they were collected, in accordance with applicable legislation;
• Limiting the processing of your Personal Data, under certain circumstances (in which case we will only process the Personal Data for the exercise and/or defense of the rights of Applus+, as the case may be);
• Objecting to the processing of your Personal Data, taking into account certain circumstances and for reasons related to your particular situation (in which case we will only process the Personal Data for compelling legitimate reasons or for the exercise and/or defense of the rights of Applus+ , as the case may be);

This includes your right to object, at any time, for reasons related to your particular situation, to our processing of your Personal Data on the basis of our legitimate interests or those of a third party, in which case we will stop processing your Personal Data unless we can rely on legitimate reasons for doing so.

• Exercising your right to data portability, which will allow you to receive and reuse Personal Data in a usable electronic format for your own purposes and for different services without hindrance to its use, including its transmission to a third party.
• Revoking, at any time, the consent you have given in relation to a specific processing.

We recommend that you contact us to update or correct your personal information as soon as it changes, or if the Personal Data we have about you are inaccurate.

Applus+, as the case may be, is committed to protecting your Personal Data as set forth in this Privacy Policy, and by virtue of applicable legislation. If you wish to make an inquiry or want to request additional information on how to exercise your rights, please do not hesitate to contact us through the following email: rgpd.automotive@applus.com

4. How do we share your personal data and with whom?

Applus+ will share your Personal Data with third parties in the following circumstances:

(a) Service providers and business partners: We will allow our service providers and business partners to access your Personal Data in the context of the services they provide us, among others, administration (e.g., invoice management), banking (e.g., providing a payment gateway for the collection of services through debit or credit cards), IT (e.g., database or software management), auditing and provision of services related to accreditations, as well as fiscal, insurance or legal services.

(b) Applus+ group entities. Applus+ may share your personal data with other companies belonging to the Applus+ Group for purposes of economic, fiscal, administrative management, reporting and internal investigation. You can consult a list of Applus+ Group entities through: www.applus.com/appluscompanies.

(c) Law enforcement agencies, judges and courts, regulatory entities, government authorities or other competent third parties. We may share your Personal Data with these third parties when necessary to comply with a legal or regulatory obligation, or to otherwise protect our own rights as well as the rights of third parties.

(d) Asset buyers and merger. We will share your Personal Data with any third party that buys, or to whom we transfer, all or almost all of our assets and business or with those with whom we carry out a merger, consolidation, integration or similar restructuring. In the event of such a sale or transfer, we will use all reasonable efforts to ensure that the entity to which we transfer your Personal Data processes them in a manner consistent with this Privacy Policy.

5. How do we protect your Personal Data?

We implement technical and organizational measures to ensure a level of security appropriate to the risk for the Personal Data processed. Said measures are intended to guarantee the continuous integrity and confidentiality of Personal Data. We evaluate these measures periodically in order to guarantee the security of the processing.

6. For how long do we keep your Personal Data?

We will keep your Personal Data as long as we maintain a relationship with you and for a period of five (5) years from that moment. We will only keep your Personal Data once said period has elapsed if we are obliged to do so in compliance with the law, or in the event that there are pending claims or complaints that reasonably require the preservation of your Personal Data.

7. Contact us

Applus+, as the case may be, is the data controller in relation to the Personal Data we collect and process.

If you have questions or doubts about the processing of your Personal Data, please contact us through: rgpd.automotive@applus.com

We are committed to collaborating with you to obtain a fair resolution regarding any claim or doubt related to privacy. However, if you consider that we have not been able to help you with your claim or doubt, you will have the right to file a claim with the Spanish Data Protection Agency through its website www.aepd.es.

8. Changes to this Privacy Policy

You have the right to request a copy of this Privacy Policy using the contact details indicated above. This Privacy Policy is subject to change, as deemed necessary from time to time.

In the event that we modify this Privacy Policy, we will notify you of the changes in those cases in which the changes to the Privacy Policy have a fundamental impact on the nature of the processing, or otherwise have a substantial impact on you, we will notify you sufficiently in advance so that you have the opportunity to exercise your rights (for example, among others, objecting to the processing).

Likewise, and to the extent that Applus+ relies on consent to carry out any of its processing activities, we will ensure to request your consent when the aforementioned changes may have a substantial impact on the processing in question, before said changes become effective.

DECEMBER 1, 2022