Privacy Policy2018-05-23T19:27:42+00:00

Privacy Policy

Last updated: 23 May 2018

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 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, and other information you provide, such as a copy of your drivers 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.

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. 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.

Purposes and Legal Bases for Our Using of Your Information

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.

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.
  • 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.

Access and Amend Your Information

You may update or correct your account information at any time by logging in to your account.

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.

Your Rights

As noted above, The Car’tell gives users several easy-to-use ways to exercise choices about their personal information.

Access Amendment, Deletion, Portability, Objection and Other Rights. If you have registered with us and wish to access or update your profile, or exercise certain opt-out rights, you may do so online by visiting the “profile” settings in your account. In addition, users may also have the right to be provided certain personal information in a commonly used format where technically feasible, and, under certain conditions, to object to or restrict our use of certain personal information. You may also contact us, to access or amend your personal information, to request that we rectify, delete or stop processing 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.

Complaints. You also have the right to lodge a complaint with a supervisory data protection authority.

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.

Links to Other Websites

The The Car’tell Platform may contain links to third-party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.

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.