Your Privacy at Lynk & Co

We value your privacy. No really, we do.

We know everyone says it, but at Lynk & Co, protecting your privacy is one of our top concerns. With openness being one of our core values, we want to give you as clear and transparent information as possible about how we use your personal data, so you can feel confident when using our services.

With this in mind, this policy will describe our guiding principles for using personal data, when, how, and why personal data is used, and what rights you, the data subject, have relating to your data. This policy applies to all our uses of personal data, e.g. collection, use, sharing, storing, etc. (any so-called processing of personal data).

At the end of this policy, we give you Information Notices about specific situations. These notices give more detailed information about how personal data will be used in connection with your various interactions with us.

Who is responsible?

Lynk & Co is responsible for making sure that your personal data is kept secure and only used in the right way (we’re the data controller). Depending on what type of interaction you have with us, the specific responsible Lynk & Co unit will differ since we have separate companies in each of the countries where we offer our services. These local companies are typically responsible for the personal data used in marketing, sales and customer relations operations (things that have a connection to your local market), whereas Lynk & CO International AB (a Swedish registered company with corporate number 559151-8161), will be responsible for all other activities (e.g. relating to product and service development, vehicle quality and safety monitoring and provision of global services). In the specific Information Notices, the responsible unit will always be indicated.

In cases where we make available services or products that are not developed or managed by Lynk & Co (i.e. third-party services), the third parties themselves are responsible for their use of your personal data. Lynk & Co takes no responsibility for these third-party services. Instead, we recommend you take part of the respective third-party terms of service and privacy policy that apply for each such third-party service.

Our approach to using your personal data

Whenever we use your personal data, we follow a set of privacy principles. These principles guide our approach to using personal data in our daily work and helps us in our goal to develop privacy friendly products and services.

Lawfulness

We do not own your personal data. We only “borrow” it when it is needed and when it is legally allowed to do so. In most cases, we need to use your personal data to be able to deliver the services that you have signed up for. Other times, we may be required to use your personal data because we are obligated to do so by law. For some activities, the use of personal data may be necessary for one or more legitimate interests of Lynk & Co. In these cases, we will evaluate the impact of such activities on your rights and freedoms and only proceed with the activities if our assessment shows that your interest is not outweighing ours. For certain specific use-cases, we will base our use on your consent. If you have given your consent to any such activity, you always retain the right to revoke that at any time. If so, we’ll stop using your data.

Data minimization

With great amounts of data, comes great responsibility. That’s why we strive, both for your and our sake, to limit our use of personal data as much as possible, whilst still being able to offer our services. We do this by not collecting more data than what is actually needed, by being clear about the purposes of using your data, and by limiting the duration of the data storage as much as possible. We also strive to integrate privacy consideration directly into our products and services, e.g. by designing them so that any added data processing is only activated on your own initiative, as well as generally limiting our exposure to your personal data by implementing pseudonymization and, where possible, anonymizing the data completely.

Transparency

We want to be as clear as possible about when, why and how we use your personal data. We will strive to provide information about our use of your personal data wherever possible and reasonably practical or otherwise required by law. This information may be provided in layers with high-level information initially showed in direct connection with whatever activity or action you plan to take that will initiative some form of processing of your personal data, e.g. making an online purchase or submitting a request on our website. We then give you more in-depth information by referencing this policy and the additional details in the specific Information Notices.

Security and integrity

Personal data can be sensitive, so we have implemented and is continually improving technical and organizational measures designed to ensure that your personal data is only shared with the right people, that it is kept correct, and that it is protected against unauthorized or unlawful disclosure. These measures include e.g. only using sufficiently secure tools for storage and transfer of personal data, encrypting data when needed, and having administrative procedures regulating the collection, use, and distribution of personal data within our organization.

How your personal data is shared

We work with third parties who help us deliver many of our services. To enable this, we may be required to also share personal data with these parties. In these situations, we only share what is necessary to enable the provision of the services.

These third parties may include other Lynk & Co units, external suppliers, financial partners, workshops, and other companies within the larger GEELY group. We may also be required by law to share data to authorities as part of a government inquiry, dispute or other legal process or request.

When we partner with third parties where data sharing is needed, we make sure that they are contractually required to commit to the same kind of privacy requirements that apply to us, and when we contract a supplier to help us deliver a service on our behalf, we employ similar contractual obligations ensuring that these suppliers only use the personal data we give them for the purpose of their assigned task and only use it in accordance with the instructions we give them. This ensures that whenever we outsource data processing, Lynk & CO retains control over the personal data.

Transfer of personal data to third countries

Where our business partners, suppliers or group affiliates are operating from a country outside the European Union (EU) or the European Economic Area (EEA), (a third country), we may be required to transfer personal data to such a third country. Whenever we transfer your Personal Data to a third country having a lower level of protection of personal data compared to the EU/EEA, we use the standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. These clauses obligate the third country recipients of the personal data to treat it in compliance with EU standards of data protection.

How long we keep your personal data

We don’t want to have personal data just lying around, so we only keep your personal data for as long as it’s needed. That need is typically linked to our obligation to deliver our services to you. For example, if you have signed up for any of our offers the personal data necessary for that service will be retained for the duration of your customer relationship with us. So, depending on the type of service, the period of retention (and what personal data it includes) will differ. In some cases, we need to keep personal data independent of such a customer relationship, e.g. to meet certain legal obligations or to be able to defend ourselves in legal disputes. But in any case, we’ll never keep your data longer than what is permitted by law.

Your data rights

Because it’s your personal data, the law gives you certain data rights allowing you to have insight and exercise control over our use of your personal data. The applicability and extent of these rights vary depending on the specific processing situation, but always gives you the right to information about how your personal data is being used. If you want to exercise any of these rights, contact us using the contact information at the end of this policy. Read below for descriptions of the rights you have.

Right to information and access

You have the right to get confirmation on whether or not we are processing personal data about you, and information about the personal data, why we’re using it, how it is shared, and for how long we store it. You can also get a copy of the personal data we have about you if you want.

Right to erasure (“the right to be forgotten”)

In some cases, you have a right to request that we delete your personal data. This is the case for example where the personal data is no longer necessary given the purposes it was collected for, or if you withdraw a consent you have given, and we don’t have any other legal reason to keep the personal data.

Right to object

You have the right to object to our use of your personal data when our ground for using it is our “legitimate interest” or when we use it for marketing purposes. In some cases, we can continue to use your personal data even if you have objected to our processing. This can be the case if we can show compelling legitimate reasons for the continued use that outweigh your interests, or if it is for the purpose of establishing, exercising or defending ourselves against legal claims.

Right to rectification

You have a right to correct or update any inaccurate personal data about you that we have and to ask us to have incomplete personal data completed. We may need to verify the accuracy of the new data you provide to us.

Right to restriction

You also have a right to request that we restrict our use of your personal data. That is the case for example when the accuracy of the personal data is contested by you, or the processing is unlawful, but you do not want us to delete it and instead you request that we restrict our use of it.

Right to lodge a complaint to a supervisory authority

You always have the right to lodge a complaint with a supervisory authority. You may do this in the EU/EEA member state where you live. For Lynk & CO International AB, the Swedish Authority for Privacy Protection (in Swedish; Integritetsskyddsmyndigheten, “IMY”) is our primary supervisory authority. But you also have the right to contact your national supervisory authority directly. You also have the right to seek a remedy from a national court.

Right to data portability

When our use of your personal data is based on your consent or on a contract, you have the right to ask us to transfer, where technically feasible, the personal data we have about you to you or to another company of your choice (“data portability”).

Right to withdraw your consent

At any given time, you have the right to withdraw any given consents to our use of your personal data.

Contact us

If you have any questions about our your personal data, or if you want to exercise any of your rights, please contact us at hello@lynkco.com.

The postal address to Lynk & Co International AB is Theres Svenssons gata 15, 417 55 Gothenburg, Sweden.

Lynk & Co has appointed a Data Protection Officer who can be contacted at dpo@lynkco.com.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about how we use your personal data.

Information notices

Below you’ll find information notices for specific situations where we process your personal data.

Lynk & Co account

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

Signing up for a membership means signing up for a Lynk & Co account. We process the personal data that you provide in connection with your registration of your Lynk & Co account and your furthe use of your account. The purpose of our processing is to administer your Lynk & Co account (from registration to eventual termination of the account), to provide you with all the functionality related to the Lynk & Co account (including the Co:lab community platform), to allow access to our services that requires a Lynk & Co account, and to communicate updates related to the Lynk & Co account.

The legal basis for our processing of your personal data in order to administer your Lynk & Co account, to provide you with all the functionality related to the Lynk & Co account, to allow access to our services that requires a Lynk & Co account is that this processing is necessary for the performance of our contract with you.

What data we process:

We process the personal data you provide when registering your Lynk & Co account (e.g. name, date of birth, country/region of residence, phone number), as well as any additional personal data you choose to add to your profile (e.g. address, date of birth, interests, profile photo). We also process information about your account (e.g. account password, customer ID, newsletter preferences, membership details).

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

We retain your personal data for as long as you choose to keep your Lynk & Co account. For personal data that you’ve provided directly to your account, you can change and remove this in your account settings at any time.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Newsletters

Who is responsible:

Lynk & Co International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process the personal data you provide when signing up for our newsletter. The purpose is to be able to send newsletter to you, and to adjust them to fit your specific market and registered interests.

We also keep statistics about how our newsletters perform (e.g. by number of openings and clicks). The purpose is to monitor the performance of the newsletters to help us improve them. If you choose to unsubscribe from our newsletter, we process that information in an “unsubscribe-list” to make sure we do not send any newsletters to you again.

Our legal basis for sending you newsletters is your consent. You can at any time revoke this consent by unsubscribing to our newsletter. Our legal basis for keeping statistics and monitoring newsletter performance is Lynk & Co’s legitimate interest. Our basis for processing your newsletter opt-out is our legal obligations.

What data we process:

We process the personal data you provide when signing up for newsletter (e.g. email, country/region of residence, newsletter interests). We also process statistical data (e.g. openings/clicks) and other account data relevant to tailor the newsletter after your interests.

How we share the data:

How long we store your data:

We will retain your data for as long as you have signed up for newsletters, or as otherwise required by law. Statistical data will be stored for up to one year from collection.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Purchase of products and services

Who is responsible:

The local Lynk & Co sales company in your country, as specified in your purchase and/or service agreement.

Why and how we use personal data:

We process the personal data you provide in connection with your order of products and/or services. The purpose of our processing is to administer your purchase from order to delivery including any necessary contacts with authorities for official reporting of the vehicle as applicable, administration of your request for related services, follow up on the delivery and to communicate updates related to the product and/or services that you have ordered.

We will also collect and process personal data relating to payment services and invoicing, such as your credit card information, to enable the fulfillment of your payment obligations. Depending on your choice of service and selected method of payment we will engage third party credit bureaus to make a credit check to ensure your eligibility for such payment options. We transfer the necessary information to these credit bureaus who then may collect additional personal data about you to be able to evaluate the credit risk (e.g. by assessing the reliability and punctuality of your payments). In addition to making credit checks, we may also conduct know-your-customer screenings (“KYC”).

If you have selected to finance your order, i.e. if you intend to apply for a consumer credit, or lease the vehicle, we will transfer your personal data to the selected finance company or leasing company, in order for you to be able to complete your financing application and your order. If you have applied for financing or leasing of your order, we will also process information on the status of your application that we receive from the financing/leasing company.

We will also process the personal data that you provide to us for the purpose of communication with you in relation to eventual recalls and other matters concerning the products and/or services. We will also process your personal data in order to be able to recognize you as a recurrent customer.

The legal basis for our processing of your personal data in order to administer your order, administration of your request for related services, to follow up on the delivery as well as status of your eventual credit application is that this processing is necessary for the performance of the contract with you. For KYC measures and other related screenings which are not required under law, our legal basis for that processing is our legitimate interest of fulfilling our KYC obligations. The legal basis for our processing of your personal data in order to communicate with you in relation to eventual recalls and other matters concerning the products and/or services as well as to recognize you as a recurrent customer is that this processing is necessary for the purposes of our legitimate interest. The legal basis for processing your personal data in relation to recalls which are performed due to a legal requirement is that this processing is necessary for our compliance with a legal obligation.

What data we process:

We process the personal data you provide when you submit your order and/or application for financing. For managing your purchase and payments, we process e.g. your name, address, date of birth, and necessary payment information such as credit card information. When performing the credit check, the personal data processed may differ depending on which country’s legislation apply but includes, in addition to the above, e.g. occupational status, net income, existing loans, salary slips and bank statements, etc. Where additional screenings may be required for KYC purposes, we may process additional personal data, including making searches in official sanction lists.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and business partners (including, if applicable, our payment service provider, financing or leasing partner, pick-up and delivery partner) for the above purposes (including credit check and sanction list checks). Your personal data will also be disclosed to Vehicle Registration Authorities when applicable.

For the purpose of credit checks, we transfer personal data to the following credit bureaus, which in turn process your personal data. Depending on your market, the specific credit bureau varies.

- Germany: Arvato/Infoscore Consumer Data GmbH. https://finance.arvato.com/icdinfoblatt
- Netherlands: Experian Netherlands B.V. https://www.experian.nl/
- Belgium: Focum België BVBA. https://www.focum.be/contact/
- Sweden: Creditsafe i Sverige AB. https://www.creditsafe.com/se/sv.html
- Spain: Experian Bureau de crédito, SAU, Badexcug. https://www.experian.es/
- Italy: Experian Italia S.p.A. www.experian.it.

In relation to our business partners located outside of EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

We will retain your personal data for the duration of your customer relationship with us. During the course of this relationship, the personal data retained will be limited to the personal data necessary for the fulfillment of the above purposes. Personal data will in any case never be stored for a longer period than what is permitted by law.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Connected services

Who is responsible:

Lynk & Co International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data to enable the delivery of the connected services and features available with your Lynk & Co vehicle and mobile app. This requires us to mainly process information about the vehicle, and not you specifically. However, your user account and corresponding account data will be used to deliver the services that you have access to, and link any technical data generated by the vehicle and/or the connected services to you as a user. The various services and features and their respective descriptions and purposes for processing personal data are listed below:

• General base connectivity and functions. We process personal data to provide internet connection to the vehicle enabling communication with the Lynk & Co cloud (e.g. to be able to send you messages from Lynk & Co to the vehicle), manage access to services and settings linked to the vehicle by keeping track of permissions and agreements connected to your user profile, and to enable smart settings which allows your personal settings to carry over to whatever Lynk & Co vehicle you log in to, e.g. in the case of car sharing.

• In-car apps support. We process personal data to provide support for in-car apps to enable e.g. installation, updates, and storing of login credentials to simplify access to Lynk & Co or third-party content and services.

• Navigation. We process personal data to provide navigation services enabling the presentation of vehicle position and route guidance to user-defined destinations, enhanced map features such as showing traffic flow and availability of parking, information transmission between your phone and vehicle to support route guidance between devices, saving destination history and favorite destinations, and allowing map updates for car deliveries.

• Vehicle uptime. We process personal data to monitor the connectivity status of the vehicle to ensure uptime, e.g. by monitoring system errors, latency and location information.

• Over-the-air downloads (OTA). We process personal data to allow the download and installation of new software, enabling new functionality and bug fixes (Over-the-air downloads).

• Digital key. We process personal data to enable the opening of the vehicle using a mobile app as a digital key.

• Emergency call (eCall). We process personal data to enable communications to emergency services. The purpose of the eCall is to only be used in emergency situations to get in contact with emergency services. The eCall do not enable any constant tracking of the vehicle. The eCall only records information about the vehicle and no directly identifiable personal data of you.

• Roadside assistance (bCall). We process personal data to enable communications to roadside assistance services.

• Help (iCall). We process personal data to enable communications with Lynk & Co for various support services.

• Smart phone connection. We process personal data to enable smart phone projection services and interactions between your phone and the vehicle (e.g. through Android Auto and Apple Carplay), as well as to enable handsfree calls (e.g. by allowing call interactions from in-car displays to see phone contacts, call history etc.).

• Journey camera. We process personal data to enable you to take photos and record videos, store these locally in the vehicle, and send them to your mobile phone via Bluetooth or wi-fi. Please note that our processing is limited to the local storage of the photos and videos and transmission between the vehicle and your phone. As further outlined in the terms of use for the Connected Services, you are responsible for ensuring that any photos and/or videos that are collected on your initiative are collected in compliance with any applicable data protection legislation (e.g. (as applicable) that you have the permission to take a photo of someone).

• Open internet. We process personal data to enable open internet access by allowing you to connect your external devices to the vehicle. In addition to Lynk & CO, our partnered internet service provider may also process personal data as part of the delivery of the internet connection, in accordance with the terms of the open internet service.

• Remote car management. We process personal data to enable you to remotely manage some vehicle functions via the mobile app, e.g. lock/unlock the vehicle, control the vehicle horn and headlights, remote engine start and pre-climatization, scheduling automatic charging, providing information about battery levels, tire pressure, and error messages. We also enable you to find your car on a map using the car localization feature, and to be notified about any triggered vehicle alarms.

• Stolen vehicle tracking. We process personal data to enable the remote tracking and immobilization of the vehicle in case of a vehicle theft, in collaboration with police authorities.

• Trip log. We process personal data to provide you with a trip log which stores information about your driving history, e.g. distance driven, fuel consumption, and other statistics.

• Voice control. We process personal data to enable you to control certain functions using voice commands, e.g. to call a certain person in your contact list by stating their name.

Our legal basis for processing your personal data for the above purposes is that it is necessary for the performance of the contract between you and Lynk & Co. Our legal basis for processing your personal data relating to the emergency call (eCall) is that the processing is necessary for our compliance with our legal obligations.

Please note that while certain services and features are not dependent on having a Lynk & Co account and are therefore accessible from the vehicle using only a guest account login, information will still be processed for the purposes above (as applicable). This information may or may not amount to personal data about the guest account user, even where no direct Lynk & Co account is linked to that data. Similarly, data collected and/or stored using the vehicle guest account will be open to all users of that vehicle’s guest account. To avoid having any data unintentionally disclosed, please refrain from collecting and/or storing any personal data or otherwise personally sensitive information using the vehicle guest account or ensure that you always reset the account after its use to delete the data.

What data we process:

To enable the connected services, we process information about you as a user e.g. your account data (who you are, and what services you have signed up for) as well as any settings or choices you’ve made that reflect your interests. This kind of personal data includes information such as:

• Your Lynk & Co account and identity (e.g. your name, contact information, etc.),

• Various codes and passwords to your different apps and services that you’ve saved,

• Personal settings you have made to the services and/or vehicle e.g. saved locations and favorites, language settings, etc.

• Search history (e.g. navigation or media related searches),

• Photos and videos that you’ve taken with the Journey camera,

• The relationship with the vehicle that you are using (e.g. if you are a month-to-month user, a car sharing user, or if you own the vehicle).

In addition to this, we also process data of a more technical nature related directly to the vehicle and/or services, and therefore information only indirectly relating to you. This includes information such as:

• Vehicle identification number (VIN),

• Static vehicle data (e.g. engine type, hardware and software information etc.),

• Dynamic vehicle data (e.g. speed, direction),

• Vehicle location data,

• Vehicle destination and route data,

• Technical Identification data (e.g. IP address),

• SIM card data,

• Various status information about vehicle condition (e.g. battery, fuel levels, and other vehicle status indicators).

How we share the data:

The vehicle connection to the Lynk & Co cloud is enabled through the help of our group affiliates and suppliers, to whom personal data is disclosed for the purpose of enabling their assigned task as service providers to our services. All personal data is stored within the EU/EEA area, but may be accessible from third countries for operational purposes. In relation to affiliates located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

Depending on the type of personal data, our criteria for retention will differ. For account data, we will retain the corresponding personal data for as long as you choose to keep your Lynk & Co account. For various service data we will retain that for the duration of your customer relationship with us. For personal data collected directly from you (e.g. saved destinations, or photos stored locally), these can be managed directly from the vehicle at your will. For various technical vehicle data, which may or may not amount to personal data, we will retain that for as long as needed to enable us to deliver our services to you, or as otherwise permitted under law.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Car sharing

Who is responsible:

Lynk & Co International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data to enable us to deliver the car sharing service. We process the information you provide when signing up for the service, including verifying the existence of a valid driver’s license, as well as any additional information necessary to manage payments and insurance. We also process personal data related to your user profile. In addition to the processing specific to the car sharing service, additional processing related to the general vehicle use apply, e.g. relating to vehicle diagnostics and connected services.

Our legal basis for processing your personal data is that it is necessary for the performance of the contract between you and Lynk & Co. In case you have access to car sharing as an employee of one of our car sharing business customers, our legal basis for processing your personal data is that it is necessary for the purpose of our legitimate interest to deliver the service under that business-to-business agreement. To the extent we process biometric image data as part of the driver’s license validation process, our legal basis for that processing is your explicit consent.

What data we process:

For the purpose of enabling the car sharing service, we process the following personal data: Name, date of birth, address, profile photo, driver’s license data (e.g. license number, license category, date of obtainment, expiry date), date of identity validation, VIN, and vehicle location (for the purpose of pickup and drop-off). We also process your credit card information, bank and transaction data to enable payments and compensations, as well as vehicle condition reports and damage logs. Your car sharing profile is also subject to a peer-to-peer rating system.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and business partners (including the supplier of the driver’s license verification service, insurance provider, financial partner and payment service provider) for the above purposes. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

Your car sharing profile is tied to your Lynk & Co account. We retain your personal data for as long as you choose to keep your Lynk & Co account. For personal data that you’ve provided directly to your account, you can change and remove these in your account settings at any time. Financial and transactional data will be kept for as long as necessary or as otherwise required under law.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Research and development of products and services

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data to better understand how to improve our products and services, e.g. by analyzing vehicle, product, customer and sales data. The processing spans a wide range of information and operations such as analyzing vehicle-recorded data to gain insights on how to enhance our vehicles' quality and its safety features. The legal basis for this processing is our legitimate interest to improve our products and services. We will generally not seek your consent unless this is deemed necessary in the individual case or required by applicable law. However, where possible, we restrict analyses to anonymized or pseudonymized data. The processing does not include any automatic decision making, such as profiling, of you.

What data we process:

The data we process for these research and development purposes encompasses a wide range of categories relating to our various services and products. For vehicle development, we may collect data about your use and interaction with functions and services on a statistical level. The general research and development work do not in itself necessitate any independent data collection, but instead makes use of existing information for these purposes. For information about these various types of data, refer to the Privacy Policy and the Information Notices.

How we share the data:

Your personal data may be disclosed to and processed by our affiliates for the above purposes. In relation to affiliates located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

The information generated from the research and development work does not in itself create any personal data subject to specific retention periods. Instead, refer to the individual Information Notices for information on how we store personal data.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Vehicle condition updates, warranty, and maintenance

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data when your vehicle communicates wirelessly with our network. The vehicle sends updates of its technical conditions twice weekly, including information about its vehicle ID, technical parameters and any applicable fault codes. The data transmitted only relates to the condition and performance of the physical vehicle and not you specifically. This information is used to automatically detect if there is a need for workshop maintenance. If this is the case, a work order will be created and sent to the relevant workshop responsible for the maintenance work. If you have experienced any issues on your own and contacted Lynk & Co directly, we may also manually create such a work order. The condition status and vehicle data will also be processed to assess and administer any warranty repair claim you make.

Our legal basis for processing this personal data is that this processing is necessary for the performance of the contract with you relating to workshop maintenance and warranty.

What data we process:

We process the vehicle identification number (“VIN”), static and dynamic vehicle data such as various technical parameters of the vehicle e.g. battery condition, oil level, and information from the event data recorder as applicable.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and business partners (including workshops, delivery partners, and parterns engaged in the fault analysis and technical support) for the above purposes. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

The vehicle condition updates are continuously overwritten with every update, meaning the data is deleted twice weekly. Individual work orders and the vehicle data associated with them are retained as long as necessary for the performance of the workshop maintenance or as otherwise required under law or automotive standards.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Booking a test drive

Who is responsible:

The local Lynk & Co sales company in your country, as specified in your test drive agreement.

Why and how we use personal data:

We process the personal data that you provide in connection with your test drive. The purpose of our processing of your data is to administer your test drive and to contact you afterwards with questions about your experience and our products and services.

The legal basis for our processing of your personal data in order to administer your test drive is that this processing is necessary for the performance of the contract between you and us for the test drive. The legal basis for our processing of your personal data for contacting you is our legitimate interest to promote our products and services for which you have shown an interest in through your booking of a test drive.

What data we process:

We process the personal data you provide when book a test drive (e.g. name, address, phone number, and email). We may also require that you show a valid driver’s license to make sure that you are eligible for driving the vehicle.

How we share the data:

How long we store your data:

We will store your personal data for as long as needed to administer your booking and to ensure that any eventual insurance cases can be managed.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Contacting us through our channels

Who is responsible:

The local Lynk & Co sales company in your country.

Why and how we use personal data:

We process your personal data when you communicate with us on any of our channels (e.g. online contact forms, website chat, email, etc.), and on our social media accounts (e.g. Facebook, Instagram). Our purpose of using your personal data is to enable our communication with you, whether that is relating to a customer service case, general questions, or other forms of contact or submissions of requests (e.g. to be contacted by Lynk & Co for business reasons, vehicle trade-in, etc.).

What data we process:

We process personal data such as your name, address, email, phone number, any information you provide in your message, Information from your profile on the social media in question (e.g. the username you have chosen for your account). We may also make internal notes if the correspondence relates to a customer service case.

How we share the data:

If you interact with us or visit our social media accounts, the social media platform that you use will process personal data about you as a user. These social media platforms are either processing your personal data based on our instructions or are processing your personal data for their own purposes. What role they have in a particular case depends on the specific platform and activity. Additionally, your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes, e.g. to the social media platform providers we use, or the providers of the means by which you contact us. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

We will store your personal data for as long as it is necessary for us to handle your question or service matter. If your message generates a case for our customer service, that information may be stored for up to 24 months.

Your comments or posts at our social media platforms can be deleted by you at any time and you can always ask us to remove your personal data from our social media platforms. We will otherwise store the personal data on the social media platform until further notice. We will remove posts or comments in breach of the rules of the platform or in conflict with legislation as soon as possible. If your message generates a case for our customer service, that information may be stored for up to 24 months.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Competitions and events

Who is responsible:

The local Lynk & Co sales company in your country.

Why and how we use personal data:

We process your personal data to administer your participation in one of our competitions or events, e.g. to manage registrations and cancellations, send communication about the event registration, reminders and follow ups. Our legal basis for processing the data is your consent.

What data we process:

We process the contact details you provide when signing up for the competition or event (e.g. your name and email address), and other information you provide to us when you participate in the competition, such as your contribution to the competition.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes, e.g. external event coordinators. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

We only store your data for the duration of the competition or event or as otherwise required for the specified purposes.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Surveys and market research

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process the personal data you provide when signing up for our survey panels. The personal data enables us in administering customer surveys and market research, e.g. by sending survey forms to you, manage the correspondence with you, and analyze the response. Our legal basis for processing your personal data is your consent. Our legal basis for assessing and analyzing your response is our legitimate interests of conducting market research.

What data we process:

We process the personal data you provide e.g. your name, age, gender, email, information on whether you have access to a car, a driver’s license, if have used any service of Lynk & Co, and other information you choose to give to us.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes, e.g. to IT-suppliers providing us with our underlying digital infrastructure. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

We will store your personal data for the purpose of sending out surveys until you notify us that you no longer wish to be a part of them. Your responses will only be stored as long as they’re needed to fulfill our market research purposes.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

GDPR data subject requests

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data to manage your data subject request e.g. to communicate with you regarding your request and manage any personal data as may be required by your request. Our legal basis for this is our legal obligation to comply with your request.

What data we process:

Your name and any other identifiers necessary for ensuring your identity, as well as any personal data of you as may be required by your request.

How we share the data:

Insofar as your personal data is processed by our affiliates and our business partners for other purposes, your request will require us to contact these third parties about your personal data. No additional personal data will be exchanged except for what may be required in order for our affiliates and business partners to accurately identify you in their systems to manage your request.

How long we store your data:

Your request case, once completed, will be logged until further notice in order for us to be able to demonstrate our compliance with the obligation to respond to the request.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Website cookies

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We use cookies to gather information about how you interact with the website. We do this to make the website work, and to gather insights that can help us improve the website and its services, e.g. the website chatbot. We also use marketing cookies on our website. This enable us to show you more relevant ads based on your interests and activities. If you want to know more about how we use cookies on our website, see our Cookie Policy .

Depending on the type of cookie, we rely on either your consent, or our legitimate interest to improve our website and services as the legal basis for processing your personal data. You can read more about how you can adjust your cookie settings in our Cookie Policy.

What data we process:

We process personal data such as user generated data (e.g. clicking and visiting history), IP-address (anonymized), Country/region of residence, technical data relating to the device you use (e.g. language settings, browser settings, time zone etc.), other information about how you have interacted with us (e.g. what services were used, login method, where and how long different pages were visited etc.) or chat history.

How we share the data:

We use a third party (Google) which on our behalf and on our instructions analyses the use of our website and therefore will receive access to your personal data. The information shared is pseudonymized and mainly comprises compiled statistics, which makes it more difficult for us and third parties such as Google to connect your browsing information to you as an individual.

As further outlined in the Cookie Policy, our use of third-party cookies will include transfer of personal data to the third parties (mainly Google, Facebook, and Microsoft). These third parties are processing the personal data for their own purposes and in accordance with information outlined in their respective Privacy Policies. For more information, read more from Google , Facebook , and Microsoft .

In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

The data retention varies between different cookies but do not exceed 24 months. See the specific retention periods in the cookie policy.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Marketing messages

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden.

Why and how we use personal data:

We process your personal data to send you direct marketing messages via email, text messages, through our app, or on social media. We send offers and invitations for events to specific customer segments based on certain parameters such as age groups, markets, or other characteristics. Our legal basis for this is your consent.

What data we process:

We process the personal data you provide us e.g. your email, country/region of residence, address, phone number, birthday, as well as personal data generated by your use of our services e.g. account information, purchase history and applicable vehicle data.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes, e.g. to social media partners and our marketing agency. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

Where our marketing is based on personal data already collected and processed, this personal data will be retained in accordance with the retention schemes applicable to those original purposes. We will process this information for marketing purposes only for as long as we are allowed to do so, whether on the basis of your consent or any other legal ground. You can at any time opt out of previously approved marketing messages, e.g. in the Lynk & Co app.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

Job applications

Who is responsible:

Lynk & CO International AB, 559151-8161, Theres Svenssons gata 15, SE-417 55 Gothenburg, Sweden, or the local Lynk & Co sales company in your country, depending on which unit is recruiting.

Why and how we use personal data:

We will store your resume and other information you provide in your recruitment profile and evaluate it for the purpose of recruitment. Our legal basis for processing the personal data is our legitimate interest to enable the recruitment process.

What data we process:

Name, contact details, and any information provided in your application.

How we share the data:

Your personal data will be disclosed to and processed by our affiliates and our business partners for the above purposes, e.g. to the provider of the recruitment platform. In relation to our business partners located outside of the EU/EEA area, we will transfer your personal data with the basis of the Standard Contractual Clauses adopted by the European Commission.

How long we store your data:

The recruitment profile you create and the information it contains will be kept up to 24 months, to allow you to apply for several jobs without having to recreate the profile. After that time, you will be asked if you want to extend it, otherwise it will be deleted.

Your rights and contact information:

For more information on your data rights, as well as contact details to Lynk & CO and the Data Protection officer, see the above sections titled Your data rights and Contact us.

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