Privacy Policy

Last updated: 25 August 2019

The Car’tell recognizes that your privacy is very important, and we take it seriously. This privacy policy (“Privacy Policy”) describes our policies and procedures about the collection, use, disclosure, and sharing of your personal information or personal data when you use the The Car’tell services as a member and as a non-member.

The Car’tell and this website record and process the data in the exclusive respect of the European General Regulations on Data Protection (GDPR). As a user, you agree to the processing of data within the meaning of this declaration. The current version of the GDPR can be found at https://gdpr-info.eu/.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.thecartell.lu

The Car’tell is the data controller for your personal information collected through the The Car’tell services. This Privacy Policy applies to activities by The Car’tell. and its affiliates and subsidiaries (collectively “The Car’tell,” “we” or “us”). For clarity, personal information or personal data means information relating to an identified or identifiable natural person.

The Information We Collect

We collect information directly from individuals, from third-parties, and automatically through the The Car’tell website. If you choose not to disclose certain personal information, it may limit your access to certain services or features, including membership registration, newsletter offering, participation to events and the ability to follow other The Car’tell members or share content on other sites.

Account and Profile Information: When you become a member and create an account and profile with the The Car’tell, we collect your name, contact information, address, email address, cookies and usage data and other information you provide, such as a copy of your driver’s license and ID card or Passport. Once you become a member, other users will be able to see certain information about your activity, such as your attendance to events and comments left in The Car’tell Private Members Group on Facebook.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Your Content: We collect and store the information for purposes of membership and/or newsletter services. For more information about what you can change, see the below section on Your Choices.

Communications: When you communicate with us (via email, through the The Car’tell website or otherwise), we may maintain a record of your communication.

Automatically Collected Information About Your Activity. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your page views, date and time of your visit, bookings, event registration and other information about your use of the The Car’tell services. We also collect and may store information that your computer or mobile device provides to us in connection with your use of the The Car’tell website such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the The Car’tell website, even if you have not created an account.

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

For more information, see the “Cookies, Pixels and Tracking” section below and our Cookie Policy.

Engagement: We collect browsing information – such as IP address and location, date and time stamp, user agent, The Car’tell cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable), and time zone, and other information about user activities on the The Car’tell website, as well as on third party sites and services that have embedded our The Car’tell pixels (“Pixels”) widgets, plug-ins, buttons, or related services. See the section below about The Car’tell Ads and Personalization for more detailed information about how our Pixels may be used by publishers or users of our advertising services (“Ad Services”) on the The Car’tell website to enable personalization, as well as your choices related to advertising and personalization. We may also receive information about you from third parties, such as other users, partners (including ad partners), or our affiliated companies.

Use of Data

The Car’tell uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Purposes and Legal Bases for Processing Personal Data under the General Data Protection Regulation (GDPR)

We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. The Car’tell uses the information we collect for our legitimate interests which include the following:

  • Provide our Services. To provide you the services we offer, communicate with you about your use of those services, respond to your inquiries, provide product information, and for other customer service purposes.
  • Personalization. To tailor the content and information that we may send or display to you and to otherwise personalize your experiences while using the The Car’tell services.
  • Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services.
  • Analytics. To gather metrics to better understand how users access and use the The Car’tell services; to evaluate and improve the The Car’tell services and personalization, and to develop new products and services.
  • Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

Transfer of data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Luxembourg and choose to provide information to us, please note that we transfer the data, including Personal Data, to Luxembourg and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Car’tell will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

How We Share Your Information

We share information as set forth below, and where individuals have otherwise consented:

  • Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service, insurance providers and support providers, as well as those who assist us in providing our services.
  • Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of The Car’tell, whose use and disclosure of your personal information is subject to this Privacy Policy.
  • Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
  • Legally Required. We may disclose your information if we are required to do so by law.
    • To comply with a legal obligation
    • To protect and defend the rights or property of The Car’tell
    • To prevent or investigate possible wrongdoing in connection with the Service
    • To protect the personal safety of users of the Service or the public
    • To protect against legal liability
  • Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of The Car’tell, its users, or others.
  • Your Content and Activity. Your Content, including your name, profile information, and certain associated activity information is available to other users of the The Car’tell services and may be viewed publicly when subscribing to events or using our services.
  • Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies, Pixels and Tracking

We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on the The Car’tell website and across third party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary of these activities. For more detailed information about these mechanisms and how we collect activity information, see our Cookie Policy.

Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in and allow them to book the cars and events via our members only platform.

Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we use to track the online movements of users of the The Car’tell website. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.

Analytics Tools. We may use internal and third party analytics tools, including Google Analytics. The third party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

How We Protect Your Information

The security of your information is important to us. The Car’tell has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using the The Car’tell website on a shared or unsecured device.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The Car’tell aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where The Car’tell relied on your consent to process your personal information.

Requests should be directed to us@thecartell.lu. Please keep in mind that certain services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information. We will respond to your request in accordance with applicable law. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Choices

You may, of course, decline to submit information through the The Car’tell Platform, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within the The Car’tell Platform about you, and otherwise amend certain privacy settings.

Emails and Communications. When you join the The Car’tell by signing up for a membership, as part of the service, you will receive the The Car’tell newsletter and members digest containing content that we believe may match your interests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you transactional emails about your account or any services you have requested or received from us.

Retention of Your Data

We will generally retain your profile and related personal information for as long as you are a member. If you wish to “be forgotten” by The Car’tell (i.e., request the deletion of your personal information from The Car’tell and the The Car’tell Platform), you will need to ask us to delete your account. If you delete your account, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

Children’s Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 13 (or under the age of 14 for anyone living in Spain or South Korea), or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing

The Car’tell uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

Links to Other Websites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at us@thecartell.lu, or send post to:

The Car’tell
70 route d’Esch
1470 Luxembourg
Luxembourg

Changes to Our Privacy Policy

If we change our privacy policies and procedures, we will post those changes on this page. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice in the The Car’tell Platform or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.