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I. PRIVACY POLICY 

We are pleased that you are using our services. We respect your privacy. Data protection and data security when using our website are very important to us. We would like to inform you about the extent to which data is collected when using our website and for what purposes we use this data. We also want to inform you about your rights in this regard. 

 II. RESPONSIBLE PARTIES 

1. Booking process: Responsible party: Licensee (see imprint) Data processor: Butler Solutions GmbH In the booking process for test drives, the organizer acts as the data protection officer responsible. The Test Drive Butler acts as a data processor. In special cases where the Test Drive Butler acts as the organizer, Butler Solutions GmbH assumes responsibility according to EU GDPR Art. 4 (7). Personal data required for the booking such as address data, driving license, names, and vehicle selection are processed by Test Drive Butler on behalf of the organizer and stored and protected in compliance with data protection regulations. 2. Invoicing: If not otherwise regulated: Responsible party: Butler Solutions GmbH The Test Drive Butler is responsible for invoicing the test drives under data protection law. In this capacity, it processes your personal data necessary for payment processing in compliance with strict data protection standards and laws. 3. Marketing: Jointly responsible: Butler Solutions GmbH, the respective licensee In marketing measures, the Test Drive Butler, the vehicle manufacturer, and the dealer jointly take responsibility for processing your personal data. These data are used for marketing purposes and for direct contact via email, chat, messenger services, or telephone. We commit to protecting your rights and your privacy and transparently disclose how your data is used for marketing purposes. 

 III. DATA PROTECTION OFFICER OF THE DATA PROCESSOR (BUTLER SOLUTIONS GMBH)

 We have appointed an external data protection officer for our company: DPO Consult GmbH Karl Pusch (Managing Director) Joanneumring 18 8010 Graz Austria Phone: AT: 0800224488 DE: 08002244880 Email: dpo@dpo.at Court of registration: GRAZ 

 IV. COMPETENT DATA PROTECTION AUTHORITY 

 The data protection authority is the supervisory authority for data protection established under the General Data Protection Regulation (GDPR) and the Data Protection Directive for the law enforcement sector in Austria. Austrian Data Protection Authority Barichgasse 40-42 1030 Vienna Phone: +43 1 521 52-25 69 Email: dsb@dsb.gv.at 

 V. OBJECTION TO PROMOTIONAL EMAILS 

 The use of contact data published under the imprint obligation for sending unsolicited advertising and information materials is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails. 

 VI. DATA PROCESSING 

 We process personal data for the following purposes, resulting from the directory of processing activities, Art. 30 EU-GDPR: - Provision of the website - Provision of the app - Operation of a webshop - Inquiries from prospects and customers - Appointment scheduling - Registration to a customer portal - Execution of billing - Communication via email and chat/messenger services - Marketing - Distribution of information - Applicant and customer management - Booking of test drives 

 VII. LEGAL BASIS FOR DATA PROCESSING 

 We process personal data on the following legal bases: Art. 6, para. 1 lit. a. EU-GDPR The data subject has given consent to the processing of their personal data for one or more specific purposes. Art. 6, para. 1 lit. b. EU-GDPR Processing is necessary for the performance of a contract to which the data subject is party, or for the execution of pre-contractual measures taken at the request of the data subject. Art. 6, para. 1 lit. c. EU-GDPR Processing is necessary for compliance with a legal obligation to which the controller is subject. Art. 49 para. 1 lit. a EU-GDPR The data subject has given explicit consent to the proposed data transfer, having been informed of the possible risks of such transfers without an adequacy decision and without appropriate safeguards (use of platforms, especially social media services operated outside the EU legal area, such as Facebook, Instagram, etc.) 

 VIII. STORAGE PERIOD 

 Unless a more specific storage period is mentioned within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you make a legitimate request for deletion or revoke consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will occur after these reasons cease to apply. 

 IX. CONTACT AND COMMUNICATION 

 IX.1. Contact form 

 a. Type and purpose of processing The data you enter will be stored for the purpose of individual communication with you. This requires the specification of a valid email address and your name. This serves to assign the request and subsequently respond to it. Providing additional data is optional. 

 b. Legal basis for processing The processing of the data entered into the contact form is based on a legitimate interest (Art. 6 para. 1 lit. f GDPR). By providing the contact form, we aim to enable easy contact for you. Your data will be stored for the purpose of processing the request as well as for possible follow-up questions. If you contact us to request an offer, the processing of the data entered in the contact form will be carried out to perform pre-contractual measures (Art. 6 para. 1 lit. b GDPR). 

 c. Data categories Contact data (name, email address, telephone number, address, fax) 

 d. Recipients Recipients of the data are internal employees and, if applicable, order processors. 

 e. Storage periods Data will be deleted no later than 6 months after processing the request. If a contractual relationship is established, we are subject to legal retention periods according to BAO and will delete your data after these periods expire. 

 f. Legal / contractual requirement Providing your personal data is voluntary. However, we can only process your request if you provide us with your name, email address, and the reason for the request. 

 g. Transfer to third countries Processing does not take place outside the European Union (EU) or the European Economic Area (EEA).

h. Withdrawal of consent You can revoke your consent to the storage of your personal data at any time with effect for the future. You can notify us of your revocation at any time using the contact option specified at the beginning of this data protection information. 

 i. Automated decision-making and profiling As a responsible company, we refrain from automatic decision-making or profiling in this data processing. 

 IX.2. Requests by email, telephone, or fax When you contact us by email, telephone, or fax, your request, including all resulting personal data (name, request), will be stored and processed for the purpose of handling your concern. We do not pass on this data without your consent. The processing of this data is based on Art. 6 Abs. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the execution of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of requests directed at us (Art. 6 Abs. 1 lit. f GDPR) or on your consent (Art. 6 Abs. 1 lit. a GDPR) if this has been requested; the consent can be revoked at any time. The data sent by you to us via contact requests remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage lapses (e.g., after completed processing of your concern). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected. 

 X. WEBSITE AND ONLINE PRESENCE 

 X.1. Data protection notice for the use of the login window for registration purposes of the respective licensee. 

 a. Type and purpose of processing The login window of the respective site, which includes the Test Drive Butler, is used to enable registrations for the respective purpose. The processing includes the collection, storage, and management of user data necessary for registration and participation. This includes managing event participation and communicating with participants. 

 b. Legal basis for processing The processing of personal data is based on Art. 6 Abs. 1 lit. b GDPR (contract fulfillment) for carrying out the registration and participation. 

 c. Data categories Processed data include personal information such as name, contact information, driving license details, and possibly further data relevant for participation. 

 d. Recipients Recipients of the data are the operator of the respective website and the entities responsible for organization and execution.

 e. Storage periods Data are stored as long as necessary for processing and any subsequent procedures. Afterwards, they are deleted, unless legal retention periods apply.

 f. Legal/contractual requirement Providing your personal data is necessary for registration and participation. 

 g. Transfer to third countries A transfer of data to countries outside the European Union is not planned. 

 h. Withdrawal of consent If the processing of your data is based on consent, you have the right to revoke this consent at any time. The revocation does not affect the lawfulness of the processing based on the consent before its revocation. 

 i. Automated decision-making and profiling In the use of the login window, there is no automated decision-making or profiling that has legal effects on you or significantly affects you in a similar way. 

 X.2. Hosting The use of a hosting provider is based on Art. 6 Abs. 1 lit. f GDPR. We have a legitimate interest in the most reliable presentation of our websites. If a corresponding consent has been requested, the processing is carried out exclusively based on Art. 6 Abs. 1 lit. a GDPR. If a corresponding consent has been requested, the processing is carried out exclusively based on Art. 6 Abs. 1 lit. a GDPR and § 25 Abs. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g., device fingerprinting) in the sense of the TTDSG. The consent can be revoked at any time. 

 X.3. Use of Contacts-Butler.com 

 a. Type and purpose of processing We use the service of Contacts-Butler.com to optimize the management of contact data and communication. Contacts-Butler.com offers functions for managing, synchronizing, and analyzing contact data, which helps us improve the efficiency of our customer interactions and gain a better overview of our business relationships. 

 b. Legal basis for processing The processing of personal data by Contacts-Butler.com is based on our legitimate interest in the efficient management and analysis of contact data (Art. 6 Abs. 1 lit. f GDPR) and/or on the basis of contract fulfillment (Art. 6 Abs. 1 lit. b GDPR), if the use of the services is contractually agreed. 

 c. Data categories Processed data include contact information (such as names, addresses, phone numbers, email addresses), communication data, and possibly further information required for contact maintenance. 

 d. Recipients Recipients of the data are Contacts-Butler.com and their subcontractors and partner companies involved in providing the services.

 e. Storage periods Data are stored as long as necessary for the purposes of contact data management and to fulfill our legal obligations.

 f. Legal/contractual requirement Providing your personal data is necessary for the use of the services of Contacts-Butler.com. 

 g. Transfer to third countries A transfer of data to countries outside the European Union may take place, with Contacts-Butler.com ensuring that appropriate data protection standards are maintained. 

 h. Withdrawal of consent If the processing of your data is based on consent, you have the right to revoke this consent at any time. The revocation does not affect the lawfulness of the processing based on the consent before its revocation. 

 i. Automated decision-making and profiling In the use of Contacts-Butler.com, there is no automated decision-making or profiling that has legal effects on the users or significantly affects them in a similar way. 

 X.4. Use of Cookies 

 a. Type and purpose of processing Like many other websites, we also use so-called "cookies." You have the option to set the prescribed preferences in the cookie consent management tool. You can view which cookies are used for which purposes in the cookie consent. Cookies are simple files that store information about our web offering and your use. These small files are optionally created automatically by your browser when you use our website and stored locally on your respective end device. This does not mean that we immediately obtain knowledge of your identity. The use of cookies serves to make the use of our offerings more pleasant for you. Therefore, we distinguish between technically necessary and non-necessary cookies: The storage duration can be found in the cookie consent tool, which is displayed when you first visit our website. Technically necessary cookies ("First Party Cookies") are required for the operation of a website and are essential for navigating and using its functions. These cookies are not permanently stored on your computer or device and are deleted when you close the browser. These are so-called session cookies or also session cookies). The following technically necessary cookies are used by us: Non-necessary cookies, on the other hand, are usually Functional Cookies, Performance Cookies, and Marketing & Third Party Cookies, which enable, for example, the number of visitors and traffic sources to be captured and counted, thus measuring and improving the performance of the website. They also serve to find out if certain pages have problems or errors, which pages are most popular, and how visitors navigate on the website. - Functional Cookies Functional cookies serve to store information you have provided, such as your username or language selection, and thus offer improved and personalized functions based on this information to the website visitor. - Performance Cookies Performance cookies are used to track visits and individual activities on websites. They serve to statistically record and evaluate the use of websites. - Marketing & Third Party Cookies Marketing & Third Party Cookies come from external advertising companies and are used to collect information about the websites visited by the user in order to create targeted advertising for the user, for example.

 b. Legal basis for processing The use of technically necessary cookies ("First Party Cookies") is possible without the consent of the website visitor and is subject to a legitimate interest in the economic operation and optimization of our website and services) within the meaning of Art. 6 Abs. 1 S. 1 lit. f GDPR. The use of non-necessary cookies, such as Functional Cookies, Performance Cookies, and Marketing & Third Party Cookies, is subject to the consent of the website visitor according to Art. 6 Abs. 1 S. 1 lit. a GDPR. 

 c. Data categories - IP address - Used browser - Used operating system - Internet connection - Session ID of the cookie 

 d. Recipients Data recipients can be found at the end of the privacy policy in the listing of the cookies used.

 e. Storage periods The user can set his web browser so that the storage of cookies on his end device is generally prevented or he is asked each time whether he agrees to the setting of cookies. Once set, cookies can be deleted at any time. How this works is described in the help function of the respective web browser. A general deactivation of cookies may lead to functional restrictions of this website. 

 f. Legal / contractual requirement The provision of your personal data in cookies is voluntary, based solely on your consent (so-called Opt-In-Cookies). You can also prevent the use of preset, technically necessary cookies (so-called Opt-Out-Cookies) via the settings of your browser. Without consent, however, the service and functionality of our website is not guaranteed. Also, individual services and services may not be available or may be limited. 

 g. Transfer to third countries Processing does not take place outside the European Union (EU) or the European Economic Area (EEA). 

 h. Withdrawal of consent You can revoke your consent to the storage of all cookies at any time with effect for the future in your browser settings. 

 i. Automated decision-making and profiling As a responsible company, we refrain from automatic decision-making or profiling when collecting cookies. 

 XI. SOCIAL MEDIA 

 XI.1. Online presence on Facebook 

 a. Type and purpose of processing We appreciate your interest in our presence on Facebook. We would like to give you an overview of which data is collected, used, and stored by us there. Social networks can generally analyze your user behavior comprehensively when you visit their website or a website with integrated social media content (e.g., Like buttons or advertising banners). By visiting our social media presence on Facebook, numerous data protection-relevant processing operations are triggered. In detail: If you are logged into your Facebook account and visit our social media presence, Facebook can assign this visit to your user account. Your personal data may also be collected even if you are not logged in or do not have an account on Facebook. This data collection may occur, for example, via cookies stored on your end device or by recording your IP address. With the help of the data collected in this way, Facebook can create user profiles in which your preferences and interests are stored. This allows interest-based advertising to be displayed to you both inside and outside of Facebook. If you have an account on Facebook, the interest-based advertising can be displayed on all devices on which you are logged in or have been logged in. Please note that we cannot trace all processing processes on Facebook. Therefore, additional processing operations by Facebook may be carried out. Details can be found in the terms of use and privacy policy of Facebook. 

 b. Legal basis for processing Processing is carried out according to Art. 6 Abs. 1 lit. f. GDPR based on our legitimate interest in the contact possibilities with our customers. The analysis processes initiated by Facebook may be based on different legal bases that Facebook must specify (e.g., consent in the sense of Art. 6 Abs. 1 lit. a GDPR). 

 c. Data categories Please refer to the privacy notices of Facebook to find out which specific data is collected and how it is used: Facebook: www.facebook.com/policy.php 

 d. Recipients - Employees of the IT department of our own company - Meta Platforms Inc. (Facebook) 

 e. Storage periods After the purpose has ceased and the use of Facebook by us has ended, the data collected in this context will be deleted. 

 f. Legal / contractual requirement Providing your personal data is voluntary. Without providing your personal data, we cannot grant you access to our offered content and services. 

 g. Transfer to third countries Processing does not take place outside the European Union (EU) or the European Economic Area (EEA).

 h. Withdrawal of consent You can revoke your consent to the storage of your personal data at any time with effect for the future. You can notify us of your revocation at any time using the contact option specified at the beginning of this data protection information. 

 i. Automated decision-making and profiling As a responsible company, we refrain from automatic decision-making or profiling in this data processing. 

 XI.2. Online presence on Instagram 

 a. Type and purpose of processing We appreciate your interest in our presence on Instagram. We would like to give you an overview of which data is collected, used, and stored by us there. We advertise our products and services on our Instagram account. There may be marked links for advertising purposes to external websites or to our websites that redirect to a sales page. Social networks can generally analyze your user behavior comprehensively when you visit their website or a website with integrated social media content (e.g., Like buttons or advertising banners). By visiting our social media presence on Instagram, numerous data protection-relevant processing operations are triggered. In detail: If you are logged into your Instagram account and visit our social media presence, Instagram can assign this visit to your user account. Your personal data may also be collected even if you are not logged in or do not have an account on Instagram. This data collection may occur, for example, via cookies stored on your end device or by recording your IP address. With the help of the data collected in this way, Instagram can create user profiles in which your preferences and interests are stored. This allows interest-based advertising to be displayed to you both inside and outside of Instagram. If you have an account on Instagram, the interest-based advertising can be displayed on all devices on which you are logged in or have been logged in. Please note that we cannot trace all processing processes on Instagram. Therefore, additional processing operations by Instagram may be carried out. Details can be found in the terms of use and privacy policy of Instagram. 

 b. Legal basis for processing Processing is carried out according to Art. 6 Abs. 1 lit. f. GDPR based on our legitimate interest in the contact possibilities with our customers. The analysis processes initiated by Instagram may be based on different legal bases that Instagram must specify (e.g., consent in the sense of Art. 6 Abs. 1 lit. a GDPR). 

 c. Data categories Please refer to the privacy notices of Instagram to find out which specific data is collected and how it is used: Instagram: help.instagram.com/155833707900388 

 d. Recipients - Employees of the IT department of our own company - Meta Platforms Inc. (Instagram) 

 e. Storage periods After the purpose has ceased and the use of Instagram by us has ended, the data collected in this context will be deleted. 

 f. Legal / contractual requirement Providing your personal data is voluntary. Without providing your personal data, we cannot grant you access to our offered content and services. 

 g. Transfer to third countries Processing does not take place outside the European Union (EU) or the European Economic Area (EEA). 

 h. Withdrawal of consent You can revoke your consent to the storage of your personal data at any time with effect for the future. You can notify us of your revocation at any time using the contact option specified at the beginning of this data protection information. 

 i. Automated decision-making and profiling As a responsible company, we refrain from automatic decision-making or profiling in this data processing. 

 XI.3. Online presence on YouTube 

 a. Type and purpose of processing We appreciate your interest in our presence on YouTube. We would like to give you an overview of which data is collected, used, and stored by us there. We advertise our products and services on our YouTube account. There may be marked links for advertising purposes to external websites or to our websites that redirect to a sales page. Social networks can generally analyze your user behavior comprehensively when you visit their website or a website with integrated social media content (e.g., Like buttons or advertising banners). By visiting our social media presence on YouTube, numerous data protection-relevant processing operations are triggered. In detail: If you are logged into your YouTube account and visit our social media presence, YouTube can assign this visit to your user account. Your personal data may also be collected even if you are not logged in or do not have an account on YouTube. This data collection may occur, for example, via cookies stored on your end device or by recording your IP address. With the help of the data collected in this way, YouTube can create user profiles in which your preferences and interests are stored. This allows interest-based advertising to be displayed to you both inside and outside of YouTube. If you have an account on YouTube, the interest-based advertising can be displayed on all devices on which you are logged in or have been logged in. Please note that we cannot trace all processing processes on YouTube. Therefore, additional processing operations by YouTube may be carried out. Details can be found in the terms of use and privacy policy of YouTube.

 b. Legal basis for processing Processing is carried out according to Art. 6 Abs. 1 lit. f. GDPR based on our legitimate interest in the contact possibilities with our customers. The analysis processes initiated by YouTube may be based on different legal bases that YouTube must specify (e.g., consent in the sense of Art. 6 Abs. 1 lit. a GDPR). 

 c. Data categories Please refer to the privacy notices of YouTube to find out which specific data is collected and how it is used: YouTube: https://policies.google.com/privacy 

 d. Recipients - Employees of the IT department of our own company - Google 

 e. Storage periods After the purpose has ceased and the use of YouTube by us has ended, the data collected in this context will be deleted. 

 f. Legal / contractual requirement Providing your personal data is voluntary. Without providing your personal data, we cannot grant you access to our offered content and services.

 g. Transfer to third countries Processing does not take place outside the European Union (EU) or the European Economic Area (EEA). 

 h. Withdrawal of consent You can revoke your consent to the storage of your personal data at any time with effect for the future. You can notify us of your revocation at any time using the contact option specified at the beginning of this data protection information. 

 i. Automated decision-making and profiling As a responsible company, we refrain from automatic decision-making or profiling in this data processing. 

 XII. DATA SECURITY 

 The personal data of each individual who is in a contractual, pre-contractual, or other relationship with our company deserves special protection. Our goal is to maintain our data protection level to a high standard. Therefore, we rely on the continuous development of our data protection and data security concepts. We therefore commit to protecting your privacy and treating your personal data confidentially. To prevent manipulation, loss, or misuse of your data stored with us, we take extensive technical and organizational security precautions, which are regularly reviewed and adapted to technological progress. This includes, among other things, the use of recognized encryption methods (SSL or TLS). However, we would like to point out that due to the structure of the internet, it is possible that the rules of data protection and the aforementioned security measures may not be observed by other persons or institutions not within our area of responsibility. In particular, data disclosed unencrypted – e.g., when this occurs via email – can be read by third parties. We have no technical influence on this. It is the user's responsibility to protect the data provided by them through encryption or in another way against misuse. 

 XIII. RIGHTS OF DATA SUBJECTS 

 If personal data of you as a user is processed, you are considered a data subject according to the GDPR. Data subjects have the following rights against the controller: - Right of access (Art. 15 GDPR) - Right to rectification or deletion of personal data (Art. 16, 17 GDPR) - Right to restriction of processing (Art. 18 GDPR) - Right to notification in connection with the rectification or deletion of your personal data or the restriction of processing (Art. 19 GDPR) - Right to data portability (Art. 20 GDPR) - Right to object (Art. 21 GDPR) - Right to revoke consent declarations. The lawfulness of the data processing carried out until the revocation remains unaffected due to the valid consent until the revocation. (Art. 7 para. 3 GDPR) - Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

 XIV. OUR RIGHT TO AMEND THE POLICIES 

 Changes in laws or changes in our internal processes may require an adjustment of this privacy policy. Therefore, we ask you to read this privacy policy regularly. The privacy policy can be accessed at any time. We therefore reserve the right to change these policies at any time in compliance with data protection regulations.