Privacy Policy

1. General principles

The company AD Tyres International SLU, company of Andorran law of form societat limitada unipersonal with the capital of 100.000,00 euros, registered with the register of trade and companies of Andorra under the number 16339, whose registered office is located Carrer Bonaventura Armengol Num . 10, Edifici Monclar, Block Num. 1, Despatx Num. 111-112, ANDORRA LA VELLA (Principality of Andorra), email: cm(a)adtyre.com, phone: +376 810 888, (hereinafter " AD Tyres ") carrying on an e-commerce activity offered through from the website https://www.tyreleader.ie/ (hereinafter the " Site ") the sale of tires and associated products.

As part of this activity, AD Tyres is required to collect online or by telephone Data that directly or indirectly identifies customers, users of the Site or any third party (hereinafter indiscriminately the " Persons Concerned " or " You ") and perform a Processing of these Data.

AD Tyres attaches great importance to the compliance of the Processing of these Data with the legislation in force and in particular with the Andorran Law 15/2003 of 18 December 2003 qualified as protection of personal data and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the " RGPD ").

You are informed that by decision of 19 October 2010, the European Commission has declared that Andorra is considered as providing an adequate level of protection for personal data transferred from the European Union.

Pursuant to Article 27 of the RGPD, AD Tyres has appointed, as representative in the European Union, the company MAXI TYRE LTD - a company incorporated under Irish law in the form of private limited company, registered in the Irish Trade Register under number 545522, headquartered at Hardcourt Center Block 3, Hardcourt Road, Dublin 2 (Ireland).

You are invited to carefully read this Privacy Policy (hereinafter the " Charter ") and to read its contents.

2. What is the definition of capitalized terms?

Words or phrases beginning with a capital letter have the definition specified below.

AD Tyres

means the company identified in the first paragraph of Article 1 .

charter

to the definition referred to in Article 1 .

Customer account

refers to the account that any customer can create from https://www.tyreleader.ie/my-account/ .

Terms of Sales

means the general conditions of Sale of AD Tyres accessible at the address https://www.tyreleader.ie/terms-and-conditions .

Data(s)

means any personal data, ie any information relating to an identified or identifiable natural person, it being understood that the person who can be identified, directly or indirectly, by reference to an identifier, such as a name, an identification number, location data, an online identifier, or one or more specific elements specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.

Bank data

to the definition referred to in Article 5 .

Order Data

to the definition referred to in Article 5 .

Geolocation data

to the definition referred to in Article 5 .

Navigation Data

to the definition referred to in Article 5 .

Third Party Data

to the definition referred to in Article 5 .

Service Editor Data

to the definition referred to in Article 5 .

Third Party Data

to the definition referred to in Article 5 .

Persons concerned)

to the definition referred to in Article 1 .

Product (s)

means the pneumatic or associated products (rims, chains, etc ...) offered for sale by AD Tyres on the Site.

rgdp

to the definition referred to in Article 1 .

Site

to the definition referred to in Article 1 .

Treatment (s)

means any transaction or set of transactions that may or may not be performed using automated processes and applied to the Data, such as collection, registration, organization, structuring, retention, adaptation or modification, extraction, consultation, use, transmission, dissemination or any other form of provision, reconciliation or interconnection, limitation, erasure or destruction.

You

to the definition referred to in Article 1 .

3. A charter for what?

The present Charter is at your disposal during the collection of Your Data in order to ensure a full transparency of your Data Processing done by AD Tyres by means of the provision of concise information, easily accessible, easy to understand and formulated in clear and simple terms.

In the event that any of the information is not sufficiently clear, we invite You to contact us at Your convenience either by sending an email to the address cm(a)adtyre.com or through the contact form available here .

The Charter applies to Your Data collected and processed by AD Tyres in the following activities and for which AD Tyres is the Processing Manager:

• Your use of the Site, including the simple navigation on it;
• the creation and use of Your Client Account via the Site;
• the purchase of Products offered by AD Tyres via the Site; or
• any contact with the customer service.

This Charter does not apply to any other Data Processing performed in a different context than that described above.

The Charter does not apply to any other Data Processing for which AD Tyres is not the Processing Manager.

4. For what legal justification Are your Data collected and used by AD Tyres?

AD Tyres makes a point of collecting and processing Your Data only on the basis of one of the following legal justifications:

• Your consent : this is a clear positive act on your part, whereby you express in a free, specific, enlightened and unambiguous way your agreement to the processing of your data;
• Execution of a contract : this is the collection and processing of your data necessary for the execution of the contract of sale between You and AD Tyres or pre-contractual measures provided to Your request (any request from Your previous part to the order and made in view of the latter);
• A legitimate interest : this is the collection and processing of Your Data for the legitimate interests pursued by AD Tyres or a third party (eg prospecting, fraud prevention, etc.), unless your interests or fundamental rights and freedoms that would require protection of Your Data (eg privacy or entrepreneurial freedom);
• A legal obligation : this is the collection and processing of your data imposed on AD Tyres by any legal or regulatory provision or judicial or administrative entity (eg the obligations imposed by the country in which you wish to visit).

5. What data is collected?

Data collected at the express request of AD Tyres

AD Tyres You expressly request the collection of Your Data at different times and in particular during:

• the use of the Site, including the simple navigation on the Site;
• the completion of an order on the Site;
• the creation of a Client Account on the Site; or
• any communication with the customer service.

When You make the order on behalf of a third party on the Site, You agree to communicate and to guarantee the consent to this Privacy Policy by the Data provided.

This Data Collected (hereinafter the "Order Data ") consists in particular of:

• Your first name ;
• Your name ;
• Your date of birth
• Your postal address
• Your email address
• Your phone number ;
• Your country ;
• Your intra-community VAT number.

In terms of payment, this Data collected on our express request (hereinafter the " Banking Data ") consist of Your credit card number, the expiry date and the CVC (or visual cryptogram located on the back of the card).

Certain Order Data (first name, last name, address, telephone number, country, email address) and the Banking Data condition the conclusion of the contract with AD Tyres. Consequently, any forbearance on your part to provide us with this Data will prevent You from finalizing Your order.

Data automatically collected by AD Tyres

AD Tyres is required to collect, especially during Your browsing on the Site, some of Your Data automatically through Your device (computer, tablet, mobile phone, etc.). This Data can be collected even if there is no order.

These Data (hereinafter the " Technical Data ") consist in particular of:

• Your IP address (the identification number assigned to Your device as part of its connection to the Internet);
• Your MAC address (physical identification number stored on your network card or network interface);
• Your IMEI number (identification number of your mobile phone);
• the operating system of your device (Microsoft Windows, Mac OS X, Android, iOS, etc.);
• Your mobile operator;
• Your Internet Service Provider
• the browser you use (Internet Explorer, Google Chrome, Firefox, etc.); or
• the time zone used by your device.

Data collected automatically through Your device also consists of Data about Your navigation (hereinafter the " Navigation Data ") such as:

• the pages you have visited;
• the date of Your visit;
• the time spent on each page visited;
• the links you have activated;
• the offers you have consulted;
• the Products you have searched for;
• the orders that You have made; or
• Your consumption habits of the Products.

Finally, the Data collected automatically through Your device may still consist of Your geolocation data (hereinafter the " Geolocation Data ") when Your device and / or your internet browser are set to that effect.

Data transmitted by social networks or other publishers of information society services

AD Tyres can eventually receive Your Data through a transmission made by the publisher of a social network (Facebook, Twitter, etc.) or other publishers of information society services including:

• Your browsing on the space dedicated to AD Tyres or the Site on a particular social network;
• Your use of features on the Site, which features would be related to a social network or other service of the information society;
• the creation of Your Client Account if You decide to Register by means of a transfer of Your Data from a social network (in particular Facebook) or a publisher of services of the information society (in particular Google).

These Data collected by AD Tyres through social networks or other publishers of information society services (hereinafter the " Service Editors Data ") consist mainly of:

• Your Order Data collected by the relevant service publisher (including photographs of You); or
• Technical Data or Navigation Data collected by the relevant service publisher.

In the event that You wish to limit the collection of this Data, You are invited to contact the publisher of the service concerned and / or to modify the confidentiality parameters of Your account associated with this service.

Data provided by third parties

AD Tyres may be required to collect Your Data through third parties with whom AD Tyres has legal and / or economic relationships, including:

• affiliated companies;
• business partners; or
• other independent sources.

These Data (hereinafter the " Third Party Data ") consist in particular of Identification Data or related to the use of a product or service proposed by the third party in question, which Data was collected and processed. by the third party concerned.

6. How are your data used?

The table below shows you the main characteristics of the treatments carried out by AD Tyres concerning Your Data.

For more information on the purposes or the data concerned, AD Tyres invites you to contact customer service, at your convenience, either by sending an email to the address cm(a)adtyre.com or by through the contact form available here .

7. How long are your data kept?

AD Tyres makes a point of keeping your Data in a form allowing Your identification for a duration not exceeding that necessary for the purposes for which they are processed.

The table below shows the retention periods for each type of Data depending on the Processing for which they are used.

8. Who are your data shared with?

AD Tyres may share some of Your Data with other entities referred to below. In any case, AD Tyres only shares this Data in the limit of what is strictly necessary to ensure the purpose (s) of the Processing of Your Data by AD Tyres or to ensure the precise and legitimate purpose (s) defined by this recipient.

Subcontractors of AD Tyres

AD Tyres is required to share some of Your Data with its subcontractors, which act in particular in the context of the supply of its Products. Sharing Your Data with these entities is required for the execution of Your order. AD Tyres only shares the Data strictly necessary for the execution of the mission entrusted to its subcontractors after having contractually guaranteed to them commitments as high as those taken in the present Charter in the protection of Your Data.

Entities of the group to which belongs AD Tyres

AD Tyres is required to share some of Your Data with other entities in the group to which AD Tyres belongs in order to know you better. These other entities are subject to commitments similar to those of AD Tyres for the protection of Your Data.

Third party service publishers

AD Tyres is required to share some of Your Data with the third party service publishers used in connection with the supply of AD Tyres Products via the Site (social media publishers, information society services, hosting providers, etc.). Sharing Your Data with these publishers is required for the operation of the relevant third party services. AD Tyres only shares the Data strictly necessary for the use of these third-party services. AD Tyres Invites you to consult the privacy policy of each of these editors.

Exceptional cases

AD Tyres may be required to share Your Data in an exceptional manner in the following cases: (i) in connection with a merger, an acquisition of all or part of AD Tyres, an assignment of assets or any other similar transaction, (ii) where such partition is imposed by law, a regulation, a competent judicial or administrative authority; or (iii) to protect the rights and / or security of an individual, to prevent or take action about illegal or alleged unlawful activities or to defend the rights, property and safety of the AD Site Tires; (iv) to execute and guarantee the commitments made by AD Tyres in Your interest in the context of this Charter.

9. Are your data transferred outside the European Union?

Your Data is processed and stored mainly on the territory of the Principality of Andorra where AD Tyres is established, which territory is located outside the European Union.

By decision dated 19 October 2010, the European Commission stated that Andorra is considered to provide an adequate level of protection for personal data transferred from the European Union.

AD Tyres has appointed the company MAXI TIRE LTD - company of Irish law of form private limited company, registered in the Irish trade register under the number 545522 whose registered office is at Hardcourt Center Block 3, Hardcourt Road, Dublin 2 (Ireland) - as a representative in the European Union in accordance with Article 27 of the GDPR.

AD Tyres can not exclude that Your Data are transferred to other territories outside the European Union (EU) and the European Economic Area (EEA) and in particular in territories where the degree of protection of personal data staff is lower compared to the European Union.

In the latter case, AD Tyres undertakes to verify the existence of measures or take the appropriate measures to ensure a satisfactory level of protection of Your Data, such as:

• a decision of adequacy of the European Commission of the country concerned;
• standard contractual clauses of the European Commission or standard contractual clauses adopted by a supervisory authority, to which the addressee submits himself;
• internal company rules;
• an approved code of conduct or an approved certification mechanism (including the binding and enforceable commitment by the non-EU recipient to apply the appropriate safeguards);
• an administrative arrangement or a legally binding and enforceable text adopted to allow cooperation between public authorities.

10. How are your data protected?

AD Tyres has implemented appropriate physical, technical, administrative, and organizational security measures to protect Your Data against unauthorized access, use, loss, accidental destruction, damage, theft or unauthorized or unlawful dissemination of such Data.

In spite of its continuous efforts, AD Tyres can not undertake to guarantee a result in terms of security of Your Data and invites you to report any difficulties mentioned above of which you would have knowledge.

To do so, you can contact customer service, at your convenience, either by sending an email to cm(a)adtyre.com or through the contact form available here .

11. What are your rights?

In accordance with the legislation in force, You have the rights listed below with respect to Your Data:

• the right of access to Your Data : this is the possibility for You to obtain from AD Tyres a copy of Your Data processed by AD Tyres and the essential characteristics of their Processing (purposes, categories of Data, recipients , shelf life, Your rights in this Data, the right to file a complaint with a supervisory authority and, if applicable, the source of the data collection and the existence of automated decision-making on the basis of these Data(s);
• the right to rectify Your Data : this is the possibility for You to obtain from AD Tyres the rectification, as soon as possible, of Your Data which would be inaccurate or, in view of the purposes of the Processing, incomplete;
• the right to the erasure of Your Data : this is the possibility for You to obtain from AD Tyres the erasure, as soon as possible, of Your Data for one of the following reasons:
  1. this Data is no longer necessary for the purposes for which it was collected or otherwise processed;
  2. You withdraw Your consent on which the Processing of such Data is based provided that there is no other legal basis for such processing;
  3. You object to the Processing of this Data under the conditions specified below with respect to Your right to object;
  4. the Data has been subject to unlawful processing;
  5. the Data must be erased to comply with a legal obligation provided for by European Union law or the French law to which AD Tyres is subject; or
  6. Data has been collected as part of the information society services offered to children.
• the right to oppose the Processing of Your Data : this is the possibility to object to a processing of your data carried out on the basis of a legitimate interest by AD Tyres (including profiling based on this justification) if this Treatment is in fact not justified by AD Tyres on legitimate and compelling grounds that would prevail over Your interests, rights and freedoms or for the finding, exercise or defense of rights in court.
  It is also the possibility for You to object to a Processing for prospecting purposes (including profiling if it is related to such prospecting).
  Finally, in terms of treatment for statistical purposes, it is the possibility of opposing such treatment for reasons relating to your particular situation.
• the right to limit the Processing of Your Data : this is the possibility for You to obtain from AD Tyres the limitation of the Treatment in one of the following cases:
  1. during the period required to verify the accuracy of the Data by AD Tyres when You dispute the accuracy of such Data;
  2. You oppose the deletion of data from unlawful processing and instead require the limitation of their use;
  3. the Data are no longer useful to AD Tyres in the context of the purposes of the Processing but remain necessary for You as part of the finding, exercise or defense of rights in court;
  4. for the time necessary to know whether the legitimate grounds pursued by AD Tyres prevail over yours when You opposed the Treatment on that basis.
• the right to the portability of Your Data : this is the possibility for You to obtain from AD Tyres the communication of Your Data provided to AD Tyres in a structured, commonly used and machine readable format and to transfer this Data to another entity (this transfer is provided by You or, if technically possible, by AD Tyres) and when the Processing performed using automated processes is based on consent or a contract;
• the right to withdraw Your consent : this is the possibility for You to withdraw Your consent to any Processing of Your Data that has been made on the basis of Your prior consent.

To exercise the aforementioned rights, You are invited to join us at Your convenience

• by sending an email to: cm(a)adtyre.com
• or by completing the contact form available here .

In order to handle your request as efficiently as possible, AD Tyres invites you to formulate it in a clear and detailed manner and attach a copy of Your identity card.

You also have:

• right to lodge a complaint with a supervisory authority : this is the possibility for you to lodge a complaint with a competent supervisory authority, in particular in the Member State in which your residence is located Your place of work or the place where the breach would have occurred, if You consider that the Processing of Data Concerning you constitutes a violation of the law.

To facilitate the exercise of this right, you will find in the table below the contact details of the supervisory authorities of the Member States.

12. How does AD Tyres collect data for minors?

Products sold by AD Tyres on its Site are not intended for minors. Consequently, AD Tyres does not deal with data relating to minors or can not assume that the data of visitors to the Site or its customers directly or indirectly concern minors.

13. What about cookies and other similar tracking technologies?

AD Tyres uses cookies and other similar technologies that may collect some of Your Data. These cookies can improve Your browsing experience on the Site, provide us with information on the operation and quality of our Site and contribute to the provision of targeted advertising.

AD Tyres collects your prior consent through a banner on the homepage of the Site during your first connection to these computer tools. Your consent is again requested by AD Tyres under the same conditions at the end of a period of thirteen months following the previous collection of Your consent.

AD Tyres strongly invites you to consult the page "Cookies" of its Site for more information.

14. Some additional elements on social networks

The Site uses plug-ins and other social networking features published by third-party companies (eg Facebook, etc.).

If you interact via plug-ins (eg by clicking on the "Like" or "Share" button), some of Your Data (including Your Technical Data and Navigation Data(s) will be transmitted and stored on a server. the third-party company that operates the social network in question. This Data will then be processed by this third party company in accordance with its terms and setting Your account open within this social network.

If You do not want a third-party company operating a social network to link the Data collected through the Site to Your open user account within the social network under consideration, You must Log out of that social network before visiting the Site.

In any case, the use of these plug-ins or buttons is managed by these third-party social media publishers and is exclusively governed by the conditions binding you to the social network of which you are a member. We invite you to read these conditions applied by these third-party social media publishers.

15. Some additional elements on geolocation

AD Tyres uses the Geolocation Data collected via your browser and / or the device with which You are visiting the Site.

Access to these Data results from the setting of these tools. AD Tyres Invites you to consult the privacy policy (or any related document) of the suppliers of these tools and / or to modify the setting of these tools before consulting the Site in case you do not wish that AD Tyres treats your Geolocation data.

16. What are the consequences of activating an external link

The AD Tyres Website may offer you external hypertext links directing you to other websites or technological tools. Access to these contents by Your activation of the external link is no longer covered by this Charter. You are therefore invited to consult the policy applied by the publisher of these contents concerning the protection of Your Data. AD Tyres is in no way responsible for the collection or processing of Your Data from these contents.

17. How will you be notified of changes to the Charter?

AD Tyres is required to periodically modify this Charter in order to take into account legislative changes concerning the protection of Your Data.

AD Tyres will inform you of any modification or update through a notification sent to Your e-mail address and / or an apparent notification on the Site.

18. How to contact us?

AD Tyres is at your disposal to answer all your questions about this Charter.

To contact us, you are invited to join us at your convenience:

• by sending an email to: cm(a)adtyre.com
• or by completing the contact form available here .