Privacy notice
Groupe Renault continues to ensure compliance with regulations on protection of personal data (hereinafter the "personal data") and puts it at the heart of its ethics, as described in its Group Personal Data Protection Policy available at https://group.renault.com/nos-engagements/le-groupe-renault-et-vos-donnees-personnelles/
Indeed, Groupe Renault believes that personal data protection is essential for building a relationship of trust with its customers. As such, it intends to ensure the greatest transparency in the personal data processing that it carries out on the personal data that its customers provide or that it collects through the various contacts its customers may have with it.
The purpose of this privacy notice is to provide you with detailed information about the conditions for the processing of your personal data by Groupe Renault to provide you the Smart Charge service, as well as the rights and options available to you to control your personal data and protect your privacy.
For more information on data processing by Renault for other services, https://www.renault.fr/donnees-personnelles.html
- 1- WHO PROCESSES YOUR PERSONAL DATA?
Renault SAS process your personal data as independent data controller. The contact details for Renault SAS’ Data Protection Officer are as follows: Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt.
- 2- WHAT PERSONAL DATA DO WE PROCESS?
"Personal data" means any information that can be used to identify you either directly (such as your name) or indirectly (e.g. using a unique customer number).
Generally speaking, we undertake to collect only the personal data necessary for each of the purposes for which we process your personal data.
The personal data we collect depends on our interaction with you and may include information about:
- Your identity and contact details (surname, first name, postal address, email address, telephone, etc.),
- Your payment and transaction data (payment type, discount granted, etc.),
- Data relating to our commercial relationship, in particular our interactions and contracts (order history, after-sales operations, service agreements, games, interaction with our call centre, etc.),
- Your vehicle identification data (brand, model, registration, VIN number, etc.),
- Your geolocation data (your consent is obtained when required by regulations),
- Data related to the use of the vehicle (mileage, journey, use of multimedia, etc.) and, where applicable, its battery (charge level, etc.),
- If you have a connected vehicle, data allowing control of the vehicle and, where applicable, its battery (locking/unlocking, pre-conditioning, battery charge programming, etc.), relating to driving mode (use of controls, acceleration, braking, etc.) or to the provision of connected services or on-board applications,
- Data needed to carry out loyalty, direct marketing, market research or survey actions (e.g. your vehicle preferences),
- Data concerning the use of our websites and mobile apps, as well as our communications (number of visits, page visited, messages opened, etc.).
As such, the data required to respond to your request or meet the needs of a contract or legal obligation is pointed out in the collection forms (in particular by asterisks). If you do not wish to provide the mandatory data, we may not be able to process your request or provide you with the relevant services.
We encourage you to keep us regularly informed in writing of any changes to your personal data.
The products and services that we offer are primarily for adults. Therefore, we do not carry out any specific processing on minors.
- 3- WHAT IS YOUR PERSONAL DATA USED FOR?
Within the context of our relationship, and in line with the context in which your personal data is collected, we may use your data to:
A - Manage our initial interactions
| Objectives | Legal basis |
|---|---|
| Follow up visits to our websites or mobile applications, and manage their operation and security, | This processing is based on our legitimate interest (to provide you with secure sites and applications) |
| Requests for information | This processing is justified by the pre-contractual relationship resulting from your request or our legal obligations (cooperation with the authorities for the recovery of fines) |
B - Manage our commercial relationship
| Objectives | Legal basis |
|---|---|
| Management of your user accounts and means of authentication | This processing is justified by the fulfilment of the agreement you have entered into with us. |
| Management of your participation to forums, communities | This processing is based on your consent. |
| Management of your complaints | This processing is based on our legitimate interests (prevention of legal action) |
| Responding to your possible requests to exercise rights in relation to your personal data (see the section on "your rights") | This processing is based on our legal obligations and may involve checking your identity |
| Management of our satisfaction surveys, management and response to your opinions, in order to improve customer satisfaction and our products and services, | This processing is based on our legitimate interests (to improve our products and services) |
| Management of our consolidated prospects/customers database | This processing is based on our legitimate interests (to have an up-to-date and consolidated overview of the data) |
| Management of your vehicle relationship, in particular the various operations carried out on your vehicle, | This processing is based on our legitimate interests (following the quality of our products) |
| A vehicle recall due to a quality problem | This processing is based on our legal obligations (regulations on defective products) and on our legitimate interests (to ensure the quality of our products) |
When you are in contact with our call centres, our objective is to best meet your demands. To improve the quality of our services and to train and assess our employees, your calls may be recorded. However, you may oppose this at any time and without reason.
C - Manage services provided by your connected vehicle and on-board applications
| Objectives | Legal basis |
|---|---|
| Ensure the cybersecurity of the systems | This processing is justified by our legitimate interests (to provide you with secure systems) |
| Activate your connected services and on-board applications, manage your accounts and associated contracts | This processing is justified by the fulfilment of the agreement you have entered into with us |
| Provide you with connected services and on-board navigation applications | This processing is based on your consent |
| Manage and provide you with services related to your battery and connected services and associated on-board applications | This processing is justified by the fulfilment of the agreement you have entered into with us |
Some connected services and on-board applications may require processing of your location data. Your consent is requested before the data is processed. You can revoke your consent and suspend this processing at any time.
We are committed to respecting your privacy, but we remind you that it is your responsibility to inform any other user or the buyer of the vehicle about the conditions of processing of their personal date by Renault.
D - Conduct studies and analyses
Studies and analyses are conducted to measure our performance, assess the quality of our products and services and the level of customer satisfaction, and to continuously improve them.
| Objectives | Legal basis |
|---|---|
| Invite you to respond to studies within the context of development of new products and services and to measure our brand image, | This processing is based on your consent |
| Produce analyses to measure our commercial performance, including the effectiveness of our marketing operations, | This processing is based on our legitimate interests (to measure the performance of our activity) |
| Research and development of our products and services | This processing is based on our legitimate interests (to improve our products and services) |
| Ensure the quality of our vehicles, parts, and services, including incident and durability studies, | This processing is based on our legitimate interests (to improve our products and services) |
E - Manage our marketing operations
| Objectives | Legal basis |
|---|---|
| Send advertising campaigns (digital or otherwise) and newsletters, | This processing is based on your consent and/or our legitimate interests (to provide you with relevant information) |
| Games and contests, events and sponsorship, | This processing is based on the contract (acceptance of the rules) |
3.3 – The length of time for which we keep your data
The length of time for which we keep your data
In determining this time, we take into account, in particular, the following:
- The length of your contract,
- The time required to process your request or complaint,
- The length of time your user account has been open, unless it has been inactive for 3 years,
- Your interest in our brands,
- The need to keep a record of your interactions with us, to effectively manage our business relationship. This period will vary depending, in particular, on whether you have bought a vehicle or a service such as repair, or whether you have only interacted with us without entering into contracts with us,
- Our legal or regulatory obligations (this is particularly the case for the technical data of our vehicles).
When we no longer need to use your personal data, it is deleted from our systems and records or made anonymous so that we can no longer identify you. However, it may be necessary to archive some of your personal data in order to be able to respond to any legal proceedings, throughout the statute of limitations provided for in the applicable legislation.
- 4- WHO HAS ACCESS TO YOUR PERSONAL DATA?
Within Groupe Renault and its network members, we ensure that only those people who are duly authorised for their functions and tasks to process your personal data are allowed access.
In order to process all or part of your personal data, we call upon trusted third-party providers acting as processors in accordance with our instructions and solely on our behalf, including:
- Hosting, operation or maintenance of our databases, websites and mobile applications,
- Provision of authentication services,
- Customer relations management (call centres, communication tools, etc.)
- Provision of services relating to our marketing, including the sending of commercial offers,
- Organisation of competitions and events,
- Performance of studies and surveys.
For all of this data sharing, we ensure that we only work with trusted companies and secure these relationships (contracts, audits, guarantees and security tests, etc.).
Finally, we may be required to communicate your personal data to third parties in order to comply with a legal obligation (e.g. to recover a traffic fine following a test drive) or an administrative or legal decision.
- 5- WHAT ARE YOUR RIGHTS?
5.1- Your rights
You have several rights under personal data protection regulations:
A right to object to the processing of your personal data, provided you have grounds connected with your particular situation, and the right to request the limitation of your personal data processing, in some cases as provided for in regulations.
A right to object to any commercial solicitation: you can ask at any time not to receive our communications related to our offers, news and events. This right may, in particular, be exercised via the unsubscribe link in each marketing email. You can also object to profiling.
A right to withdraw your consent at any time, for the purposes for which we obtained your consent.
A right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about 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 (including the data that is used, for what purposes, etc.) and a copy thereof.
A right of rectification: you have the right to correct your data if it is inaccurate or incomplete, despite our efforts to keep it up to date, enabling us to comply with our obligation to have up-to-date data about you.
A right to the portability of your data, i.e., under certain conditions, the right to receive the personal data you have provided to us, in a structured, commonly used computerised format, and for it to be transmitted to a third party if technically possible.
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 light of our contractual or legal obligations (contract in progress) (prevention of legal action in particular).
A right to define either general or specific guidelines regarding certain types of processing, with respect to the retention, deletion and communication of your personal data in the event of your death. You may change or delete these guidelines at any time. You may share these special guidelines with us by writing to the address below.
Finally, you have the right to lodge a complaint with CNIL about the processing of your personal data. We encourage you to contact us prior to any claim, so that we may attempt to resolve your problem together.
5.2- How do I exercise them?
5.2- How do I exercise them?
To exercise any of your rights, you can send us your request at any time via the form https://www.renault.fr/vos-droits.html or by email dpo@renault.com or by post to Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt. We may request certain information or documents (identity document, vehicle registration document) when we fail to identify you or to identify your vehicle data.
You have the right to register free of charge on the Bloctel opt-out list, managed by the company Opposetel, to no longer receive unsolicited sales or marketing calls. However, registration on this list does not prohibit us from contacting you for marketing purposes during the term of your agreement with us, unless you have specifically exercised your right to object to receiving commercial offers from us.
- 6- HOW IS YOUR PERSONAL DATA KEPT SECURE?
Your personal data is stored on secure servers. We put in place, and require from our processors and partners, appropriate data security and data protection measures in line with the latest technologies.
When personal data processing involves transferring data, we ensure that this transfer is carried out under appropriate conditions that ensure an adequate level of protection, security and confidentiality.
When a digital account is created, entering a password that respects our security standards is mandatory and is part of our privacy policy. It is your responsibility to keep it secret.
Whenever possible, your data is processed in the European Economic Area (EEA). However, as some of our service providers or their processors are located in countries outside of the EEA, your personal data may be processed in those countries. Some of these countries may have different personal data regulations from those of the European Union. In such a case, (i) we pay particular attention to ensuring that this transfer is carried out in accordance with the applicable regulations and (ii) we put in place safeguards ensuring an adequate level of protection of your privacy and fundamental rights (in particular by using the European Commission's standard contractual clauses). Upon simple request sent to the address indicated in the "What are your rights?" section, we can provide you with more information on such transfers (in particular the European Commission’s standard contractual clauses).
- 7- MODIFICATION OF INFORMATION
We may change this information from time to time. We will inform you and/or seek your consent whenever necessary or required. We therefore recommend that you consult this policy each time you visit our website in order to review the latest version.
Version 01 updated on September 3rd 2020. This new version is a major overhaul of the previous version. It is more accessible and more comprehensive. Here you can find all the terms and conditions governing use of your personal data (in particular the complete list of our purposes). The processing of your personal data for connected services and on-board applications is now included in this policy. We provide you with new information about profiling. This version also provides more transparency about the recipients of your personal data, within or outside our group.