1. GENERAL PRINCIPLES

The company AD Tyres International SLU, a company under Andorran law in the form of a limited liability company with a capital of 1,000,000 euros, registered in the Andorra Trade and Companies Register under number 16339, with its registered office at Carrer Bonaventura Armengol Num. 10, Edifici Monclar, Bloc Num. 1, Despatx Num. 111-112, ANDORRA LA VELLA (Principality of Andorra), email: dpo@adtyre.com, phone: +376 810 888, (hereinafter referred to as "AD Tyres") carrying out an e-commerce activity, offers the sale of tyres and related products through the website https://www.tyreleader.ie/ (hereinafter referred to as the "Site").

Within the framework of this activity, AD Tyres may collect online or by telephone Data that directly or indirectly identifies customers, users of the Site or third parties (hereinafter indistinctly referred to as the "Data Subjects" or "You") and to carry out one or more Processing(s) of these Data. The collection by AD Tyres of the Data of the Data Subjects is never carried out indirectly, i.e. from a third party source.

AD Tyres, whose contact details are mentioned above, is responsible for the processing of the Data insofar as it determines the purposes and means of this Processing.

For certain Banking Data, AD Tyres shares the responsibility for processing with GoCardless SAS, a simplified joint stock company registered in the Paris Trade and Companies Register under number 834422180, whose registered office is located at 7 rue de Madrid in Paris (75008). Further information on how GoCardless handles Your Banking Data and Your data protection rights is available here.

With regard to certain Browsing Data collected by cookies, AD Tyres shares the responsibility for their Processing with third party companies, a list of which and further details can be found on the cookie page.

AD Tyres has appointed a Data Protection Officer pursuant to Article 37 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the "GDPR") whose contact details are dpo@adtyres.com.

The Data collected by AD Tyres is more specifically processed by the branch of AD Tyres established in the territory of Malta, namely AD TYRES INTERNATIONAL EU, registered under the number OC 1277, whose registered office is located at Level 3, (Suite No. 2407), Tower Business Centre, Tower Street, Swatar, BIRKIRKARA BKR 4013 (Malta)

These Data Processings are therefore considered as carried out on the territory of the European Union pursuant to Recital 22 and Article 3.1 of the GDPR and are subject to this legislation.

In addition, the Malta Data Protection Act 2018 (Cap 586) is also applicable to the Processing of Data by virtue of section 4(2)(a) of that Act.

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

2. WHAT IS THE DEFINITION OF CAPITALIZED TERMS?

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

AD Tyres

means the company identified in the first paragraph ofArticle 1.

Charter

has the definition referred to inArticle 1.

Customer account

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

Data

means any personal data, i.e. any information relating to an identified or identifiable natural person, it being understood that an identifiable 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 his or her physical, physiological, genetic, mental, economic, cultural or social identity.

Banking data

has the definition referred to inArticle 4.

Order Data

has the definition referred to inArticle 4.

Navigation Data

has the definition referred to inArticle 4.

Technical Data

has the definition referred to inArticle 4.

Person(s) concerned

has the definition referred to inArticle 1.

Product(s)

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

GDPR

has the definition referred to inArticle 1.

Website

has the definition referred to inArticle 1.

Treatment(s)

means any operation or set of operations carried out or not carried out using automated processes and applied to the Data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction.

You

has the definition referred to inArticle 1.

3. WHAT IS THE PURPOSE OF A CHARTER?

This Privacy Policy is made available to You at the time of collection of Your Data in order to ensure full transparency of the Processing of Your Data carried out by AD Tyres by means of the provision of concise, easily accessible, easy to understand information 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 dpo@adtyre.com or by using the contact form accessible here.

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

• Your use of the Site, including browsing the Site;
• the creation and use of Your Customer Account via the Site;
• the purchase of Products offered by AD Tyres via the Site; or
• any contact with customer service.

This Policy does not apply to any other Data Processing carried out in a context other than that described above and for which AD Tyres is not the Data Controller.

4. WHAT DATA IS COLLECTED?

DATA COLLECTED AT THE EXPRESS REQUEST OF AD TYRES

AD Tyres expressly requests the collection of Your Data at various times and in particular during :

• use of the Site;
• placing an order on the Site;
• the creation of a Customer Account on the Site; or
• any communication with customer service.

The Data collected (hereinafter the " Order Data ") consists in particular of :

• Your first name ;
• Your name ;
• Your date of birth ;
• Your postal address ;
• Your e-mail address ;
• Your telephone number ;
• Your country ;
• Your intra-community VAT number.

For payment purposes, this Data collected at our express request (hereinafter the " Banking Data ") consists of Your credit card number, the expiry date and the CVC (or visual cryptogram located on the back of the card), which are transmitted to the payment service providers: Checkout.com, Hipay or Braintree.

As regards payment by the Paypal service provider, the banking data are directly collected by this company from You when creating your account. The Paypal company is then solely responsible for processing this data.

We use GoCardless to manage direct debits via Your IBAN. Further information on how GoCardless handles your Banking Data and your data protection rights is available here.

Certain Order Data (first name, surname, address, telephone number, country, e-mail address) and Bank Data are necessary for the conclusion of the contract with AD Tyres. Consequently, any failure on Your part to communicate these Data to us will prevent You from finalising Your order.

DATA COLLECTED AUTOMATICALLY BY AD TYRES

AD Tyres may collect, in particular during Your navigation on the Website, some of Your Data automatically through Your device (computer, tablet, mobile phone, etc.). This Data may be collected even if no order is placed. This collection is generally carried out using cookies.

This Data (hereinafter the " Technical Data ") consists 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 (your mobile phone identification number) ;
• the operating system of Your device (Microsoft Windows, Mac OS X, Android, iOS, etc.);
• Your mobile phone operator ;
• Your Internet Service Provider ;
• the browser You are using (Internet Explorer, Google Chrome, Firefox, etc.); or
• the time zone used by Your device.

The Data collected automatically through Your device also consists of Data about Your browsing (hereinafter " Browsing 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 are looking for;
• the orders You have placed; or
• Your consumption habits of the Products.

5. WHY IS YOUR DATA USED?

Personal data may only be processed if the processing is based on :

• a legal justification as referred to in Article 6.1 GDPR (consent, performance of contract, compliance with a legal obligation, safeguarding vital interests, public interest task or legitimate interest of the controller); and
• explicit, legitimate purpose( s) determined by the controller.

The table below lists the Processing carried out by AD Tyres with the purpose, legal justification and Data concerned for each of them.

6. HOW LONG WILL YOUR DATA BE KEPT?

AD Tyres makes it a point of honour to keep Your Data in a form that allows Your identification for no longer than is necessary for the purposes for which they are processed.

The table below shows you the retention periods for each type of Data according to the Processing for which it is used.

7. WITH WHOM IS YOUR DATA SHARED?

AD Tyres may share some of Your Data with other entities mentioned below. In any case, AD Tyres will only share this Data to the extent that 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.

ENTITIES OF THE GROUP TO WHICH AD TYRES BELONGS

AD Tyres may share some of Your Data with other entities of 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.

SUBCONTRACTORS AND THIRD-PARTY SERVICE PROVIDERS

AD Tyres may share some of Your Data with subcontractors and/or third party service providers used in the context of the provision of AD Tyres products and services via the Site. The sharing of 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 these entities after having contractually ensured that the commitments of these entities are as high as those taken in the present Charter as regards the protection of Your Data.

These are mainly the following entities:

• GROUPE CONSEIL ET GESTION (technology outsourcing)
• OVH (website hosting)
• HOTJAR (analytical cookie)
• GOOGLE (advertising cookie)
• MICROSOFT (advertising cookie)
• CHECKOUT.COM (payment service provider)
• HIPAY (payment service provider)
• BRAINTREE (payment service provider)
• GOCARDLESS (payment service provider)
• PAYPAL (payment service provider)
• DPD (delivery service provider)
• GLS (delivery service provider)
• UPS (delivery service provider)
• DHL (delivery service provider)
• SEUR (delivery service provider)
• CHRONOPOST (delivery service provider)
• BOOMERANG (delivery service provider)
• TNT (delivery service provider)

These are also the partner garages, a list of which can be found here.

EXCEPTIONAL CASES

AD Tyres may exceptionally share Your Data in the following cases: (i) in the context of a merger, an acquisition of all or part of AD Tyres, a transfer of assets or any other similar transaction, (ii) when such sharing is required by law, regulation, a competent judicial or administrative authority ; or (iii) to protect the rights and/or safety of an individual, to prevent or take action regarding illegal or suspected illegal activities or to defend the rights, property and safety of the AD Tyres website; (iv) to perform and secure the commitments made by AD Tyres in Your interest in the framework of this Charter.

8. IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

Your Data is processed and stored primarily on the territory of Malta, which territory is located in the European Union.

However, the company AD Tyres, established in the Principality of Andorra, outside the European Union, has access to this Data.

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

Furthermore, AD Tyres cannot exclude that Your Data may be transferred to other territories outside the European Union (EU) and the European Economic Area (EEA) and in particular to territories where the level of protection of personal data is lower than in the European Union.

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

• an adequacy decision by the European Commission of the country concerned;
• European Commission standard contractual clauses or standard contractual clauses adopted by a supervisory authority, to which the recipient is subject and of which you can ask us for a copy if they have been formally signed;
• internal company rules;
• an approved code of conduct or an approved certification scheme (including a binding and enforceable commitment by the non-EU recipient to apply appropriate safeguards);
• an administrative arrangement or legally binding and enforceable text made to enable cooperation between public authorities.

With regard to these main partners of AD Tyres, the following are the countries of destination of the data and the appropriate safeguards adopted.

9. HOW IS YOUR DATA PROTECTED?

AD Tyres has put in place appropriate physical, technical, administrative and organisational security measures to protect Your Data against unauthorised or unlawful access, use, loss, accidental destruction, damage, theft or dissemination.

Despite its continuous efforts, AD Tyres cannot guarantee a result in terms of the security of Your Data and invites You to report any difficulties of which You are aware.

To do so, you can contact customer service, at Your convenience, either by sending an e-mail to dpo@adtyre.com or by using the contact form accessible here.

This site is protected by reCAPTCHA, and Google's privacy policy and terms of use apply to this service.

10. WHAT ARE YOUR RIGHTS?

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

• the right to access Your Data:
  

  This is the possibility for You to obtain confirmation from AD Tyres that Data concerning You are or are not being processed as well as access to the said Data and to the following information: purposes, categories of Data, recipients or categories of recipients, duration of conservation or the criteria for determining this duration, Your rights concerning this Data, the right to lodge a complaint with a supervisory authority and, if applicable, the source of the collection of the Data and the existence of automated decision-making on the basis of this Data.

  You also have the right, where Your Data is transferred to a third country or to an international organisation, to be informed of the appropriate safeguards with respect to that transfer.

  Pursuant to the right of access, AD Tyres will provide You with a copy of the Data and may charge a reasonable fee based on administrative costs for any additional copies You request. If You make the request electronically, the information will be provided in a commonly used electronic form, unless You request otherwise.

• 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 are inaccurate or, taking into account the purposes of the Processing, incomplete (You may provide an additional declaration for this purpose);

• the right to erasure of Your Data:
  

  This is the possibility for You to obtain from AD Tyres the deletion, as soon as possible, of Your Data for one of the following reasons

  • such Data are no longer necessary for the purposes for which they were collected or are processed in another way;
  • You withdraw Your consent on which the Processing of such Data is based provided that there is no other legal basis for such Processing;
  • You object to the Processing of this Data under the conditions specified below regarding Your right to object;
  • the Data has been unlawfully Processed ;
  • the Data must be deleted to comply with a legal obligation to which AD Tyres is subject; or
  • the Data was collected in the context of the provision of information society services to children.

  If the Data requested to be deleted has been made public by AD Tyres, reasonable measures, taking into account the available technology and the costs of implementation, shall be taken, including technical measures, to inform the data controllers who process this Data that You have requested the deletion by them of any link to this Data or of any copy or reproduction thereof.

  This right to erasure does not apply to the extent that the Processing is necessary:

  • the exercise of the right to freedom of expression and information;
  • to comply with a legal obligation requiring the processing laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the field of public health;
  • for archival purposes in the public interest, for scientific or historical research purposes or for statistical purposes, insofar as the right to erasure is likely to render impossible or seriously compromise the achievement of the purposes of such Processing; or
  • the establishment, exercise or defence of legal claims.
• the right to object to the Processing of Your Data:
  

  This concerns the possibility to object to the Processing of Your Data carried out on the basis of a legitimate interest by AD Tyres (including profiling based on this justification) if this Processing is not in fact justified by AD Tyres on legitimate and compelling grounds which would prevail over Your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

  This also includes the possibility for You to object to Processing for the purpose of prospecting (including profiling if it is linked to such prospecting).

  Finally, with regard to Processing for statistical purposes, this concerns the possibility of objecting to such Processing for reasons relating to Your particular situation, unless the Processing is necessary for a task in the public interest.

• the right to limit the Processing of Your Data :
  

  This is the possibility for You to obtain from AD Tyres the limitation of the Processing in one of the following cases:

  1. during the period necessary for AD Tyres to verify the accuracy of the Data when You dispute the accuracy of the Data;
  2. You object to the deletion of Data from an unlawful Processing and demand instead the restriction 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 in the context of the establishment, exercise or defence of legal rights;
  4. for the period necessary to determine whether the legitimate reasons pursued by AD Tyres prevail over Yours when You have objected to the Processing on this basis.

  In case of restriction of Processing, the Data may, with the exception of storage, only be processed with Your consent or for the establishment, exercise or defence of legal claims, or for the protection of another natural or legal person, or on important grounds of public interest of the Union or of a Member State.

  You will be informed by AD Tyres of the lifting of the restriction before it becomes effective.

• the right to 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 carried out by You or, if technically possible, by AD Tyres) and this, when the Processing is carried out with the help of automated processes and is based on consent or on 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 was carried out on the basis of Your previous consent. Withdrawal of consent does not affect the lawfulness of the Processing based on the consent given prior to such withdrawal.

To exercise the above rights, You are invited to contact us at Your convenience:

• or by sending an email to: dpo@adtyre.com
• or by completing the contact form here.

In order to process Your request as efficiently as possible, AD Tyres invites You to formulate it in a clear and detailed manner. If there is any doubt about Your identity, AD Tyres may ask for additional information to confirm Your identity.

You also have the :

• right to lodge a complaint with a supervisory authority :
  

  the possibility for You to lodge a complaint with a competent supervisory authority, in particular in the Member State in which You are habitually resident, where You work or where the breach is alleged to have occurred, if You consider that the Processing of Your Data constitutes a breach of the law.

To make it easier for you to exercise this right, we invite you to consult the list of supervisory authorities here.

11. HOW DOES AD TYRES COLLECT DATA ON MINORS?

The Products sold by AD Tyres on its Site are not intended for minors. Consequently, AD Tyres does not process any Data relating to minors or assume that the Data of visitors to the Site or its customers directly or indirectly concern minors.

12. WHAT ABOUT COOKIES AND OTHER SIMILAR TRACKING TECHNOLOGIES?

AD Tyres uses cookies and other similar technologies, which may collect some of Your Data. These cookies allow us to improve Your experience of browsing the Site, to provide us with information about the operation and quality of our Site and to assist in the provision of targeted advertising.

AD Tyres collects Your prior consent by means of a banner on the home page of the Site when You first connect to these computer tools. Your consent is again requested by AD Tyres under the same conditions at the end of a thirteen month period following the previous collection of Your consent.

AD Tyres invites You to consult the "Cookies" page of its Site for further information.

13. HOW WILL YOU BE NOTIFIED OF CHANGES TO THE CHARTER?

AD Tyres may periodically modify the present Charter in order to take into account the legislative evolutions concerning the protection of Your Data.

AD Tyres will inform You of any changes or updates by means of a notification sent to Your e-mail address and/or a notice displayed on the Site.

14. HOW TO CONTACT US?

AD Tyres is at Your entire disposal to answer all Your questions about the present Charter.

To contact us, You are invited to join us at Your convenience:

• or by sending an email to: dpo@adtyre.com
• or by completing the contact form here.