Privacy Policy CAR FOR YOU AG

CAR FOR YOU AG (hereinafter referred to as CAR FOR YOU" or "we") is a joint venture of TX Group Ltd, Werdstrasse 21, 8004 Zurich, Switzerland (hereinafter referred to as "TX Group") and AXA Versicherungen AG, General-Guisan-Strasse 40, 8400 Winterthur, Switzerland (hereinafter referred to as "AXA"). CAR FOR YOU operates under its internet platform www.carforyou.ch (hereinafter referred to as "carforyou") a web-based online marketplace for vehicles on which both private users and commercial customers can place or view advertisements in the used vehicle and new car sectors and make use of related services. This privacy policy informs you about how CAR FOR YOU treats data, which data is processed about you, whether when using our websites and mobile applications (hereinafter also referred to as "digital offers" or "portals") or otherwise. With regard to these portals, we are responsible for the processing of your personal data and the compatibility of data processing with applicable law. In doing so, we comply with the applicable data protection regulations. "Personal data" means any particulars relating to the personal or material circumstances of an identified or identifiable natural person. This means that it is information that can be personally attributed to you and can say something about you. In these data protection provisions, the phrase "your data" is also used for this purpose. “Processing" means any handling of your data, including in particular the collection, storage, administration, use, transmission, disclosure or deletion of your data. Please note that the following versions may be modified from time to time. We therefore recommend that you consult this privacy policy regularly. Third-party websites that can be accessed via our portals are not subject to the principles set out here. We assume no responsibility or liability for the observance of data protection by third-party websites. The following discloses what personal information we collect and store about you when you use our portals and services, how we use that information, and with whom we may share it if necessary. You will also receive information on the rights you have in relation to us with regard to the use of your data:

1. Scope and Purpose of the Processing of Personal Data

a. When Visiting our Portals If you use our digital offers without further information from yourself, e.g. as a visitor, the web server technology used by us automatically logs general technical visit information in what are known as log files. This includes, among other things, the IP address of the device from which the visit was made, information about the browser type, the internet service provider and the operating system used, which digital offers were accessed on our website, the device ID, reference/exit pages, and the time and duration of the visit. This information is collected and processed for the purpose of enabling the use of our websites (establishing a connection), guaranteeing and increasing the security and stability of our systems and offers, analysing the use of our offers and services, collecting general demographic information and enabling the optimisation of our website (in particular, but not exclusively, product improvements, marketing measures, target-group-specific advertising, etc.) and for internal statistical purposes. Identification of the user does not take place. Likewise, no connection is established between this automatically collected information and personal data stored by us. If you send a message to a third party (e.g. an advertiser) via a corresponding function of our portals, it may be stored by us. Any personal data (e.g. email address, telephone number, message) you provide when using a service or with a message may be used by us for marketing and analysis purposes, for example. More detailed information on the processing of personal data for marketing and analysis purposes can be found in point 4 below. If you use a mobile device to access our portals, we will ask for your consent before using GPS or other tools to determine your geographic location. In addition, we use cookies (TAMEDIA, AXA, CAR FOR YOU) and analysis tools (e.g. Google Analytics Suite) when you visit our portals. Further information on this can be found under point 9 and point 10 of these data protection provisions. b. When Registering and Signing the Contract For personalised services, areas protected from access or for the processing of enquiries and administration of your subscriptions, your registration and thus the setting up of a user account may be necessary. If you use our products and services as a dealer, it may also be necessary to conclude a written contract. In all these cases, certain personal data is collected. This applies, for example, to the following:

  • Your email address

  • Password

and, depending on the context and offer, further information such as:

  • First and last name

  • Address (complete postal address, postcode, city)

  • Telephone number

  • Date of birth

  • Gender

  • Information on subscribed newsletters or other advertising

  • Language preferences

In addition to the information marked as mandatory for the use of a specific digital offer, you may voluntarily enter and store further personal data. We use the data to process and administer our digital offers, to check the plausibility of the data entered, i.e. to substantiate, structure the content of, process and amend the contractual relationships concluded with you regarding your user account and, in the case of chargeable services, to properly issue invoices. If you post contributions (comments, photos, videos, etc.) to share with other users via the appropriate functions of our portals, these can be published by us and thus made accessible to the general public. This also applies to your user name or any nickname you may have chosen for this purpose. We would like to point out that such data, once published on the internet, may continue to be retrievable by third parties, for example via search engines, even in the event of deletion or anonymisation initiated by you or us. By confirming during completion of the registration process the collection and modification of your user account details or by signing the contract, you are guaranteeing the accuracy of the details you have entered. c. During the Use of the Portals as a Registered User During the use of our portals by you as a registered user, we collect data for statistical reasons in order to enable the smooth functioning of the portals as well as for the analysis, optimisation and personalisation of the use of our offers and services. We collect data on whether and how you use our digital offers, in particular which functions and which advertising you use and how. Further information on the processing of this personal data can be found in point 1.d and point 4 below. If you use our portals as a registered user, statistical data may be visible to other registered users and recorded and evaluated by us. d. When Obtaining a Service If you obtain service, it is mandatory to provide data such as first and last name, address (complete postal address, postcode, city) and any other data, as we need this to process the contract with you. We may pass on your contact details to potential interested parties of the advertised products in order to process the contact. If you choose an online payment option, such as credit card or PayPal, to purchase a paid service, payment will be made through the provider's online payment system. In this case, the processing of personal and payment data takes place directly via the provider of the respective payment system. We do not know and do not store your payment data. The data protection regulations of the respective provider of the online payment system also apply in each case. If you are registered and have a user account, we can store your data in the user account for the next conclusion of contract. In any case, we store all information on your current and previous contracts, i.e. the products, services, the number of products and services per purchase, the payment amount. We are entitled to use this information for marketing and analysis purposes. Further information on marketing and analytical purposes can be found in point 4 below. e. When Participating in Prize Draws or Competitions (Events) We use the data provided by you to organise and conduct such events and to notify and/or publish the winners on our portals, by means of direct notification or on social networks. If you have made this possible for us, we may use and pass on your data in accordance with points 2, 3 and 4. f. On User Surveys and Market Research

We use the data you provide exclusively to improve the user experience and to further develop our products. The results consist exclusively of aggregated and anonymous data. If you have given your consent, you may also be contacted by other companies affiliated with us (in particular TX Group companies and AXA; a complete list of the companies concerned can be found here*), for example to participate in other user surveys.

*360yield.com 3lift.com a.rfihub.com addthis.com adnxs.com adscale.de advertising.com amazon-adsystem.com analytics.yahoo.com assets.carforyou.ch bidr.io bidswitch.net casalemedia.com cdglb.com cookiebot.com d.turn.com doubleclick.net dt.adsafeprotected.com everesttech.net google.com ih.adscale.de mathtag.com media.net omnitagjs.com openx.net outbrain.com pixel.adsafeprotected.com pixel.mathtag.com pubmatic.com secure.adnxs.com segment.prod.bidr.io sharethrough.com sslwidget.criteo.com sync.outbrain.com tagger.opecloud.com tpc.googlesyndication.com twiago.com undertone.com www.carforyou.ch www.google-analytics.com www.google.ie yahoo.com

2. Direktmarketing und Online-Werbung

This concerns both the personalisation of advertising by email, such as emails with general information or of an advertising nature (newsletter), by telephone, post, text messages, picture messages and on instant messaging services as well as the delivery of personalised content and advertising on our portals. For this purpose, we can automatically evaluate known information about your usage behaviour on our portals so that we can prevent you from receiving inappropriate advertising. For more information on this processing, see point 4. You can also subscribe to one of our newsletters. Your email address can also be used for our own advertising purposes until you unsubscribe from the newsletter. At the end of each email sent by us there is a link to unsubscribe from the newsletter at any time. We are entitled to entrust third parties with the technical processing of advertising measures and advertising on our behalf and are entitled to pass on your data for this purpose (further information on this under point 3 below).

3. Disclosure of Data to Third Parties

We cooperate with other companies or individuals and may commission other companies or individuals to process and store data. They may have access to your personal data or usage data, but only to the extent necessary to perform their duties. We may use information collected from you and, as part of our usage measurements in accordance with point 1 above, pass on personal data about you or your user account to companies affiliated with us, namely TX Group companies and AXA (a complete list of the companies concerned can be found here*) for the evaluation, improvement and demand-oriented design of our services, for customer care, for personalisation and for marketing purposes. The purpose of data transfer to AXA is, in particular, intended to be able to offer you AXA insurance products which are suitable and tailored to your needs in connection with the vehicles advertised on carforyou. Data processing by companies affiliated with CAR FOR YOU is described in more detail in point 4 below.

The passing on of data to third parties as described above under point 3 paragraphs 1 and 2 is done using pseudonymised or anonymised data. This means that the data can no longer be assigned to you without the involvement of additional information. Together with the companies affiliated with us (in particular companies of the TX Group as well as AXA [a complete list of the companies concerned can be found here*]), we ensure contractually and by means of technical and organisational measures that personal identification is no longer possible.

In addition, we pass on your data to third parties as far as this is necessary for the execution of the contract. This concerns in particular the data that you are required to provide as an advertiser or interested customer, which we forward to the respective interested or offering dealer for the purpose of establishing contact and possible completion of business. We may also pass on the necessary data to other service providers for the purpose of executing the contract. These service providers use your data exclusively for order processing and not for further purposes. Insofar as this is necessary for the purposes specified in clause 1 of this section, the data may also be passed on abroad. For further information on transfers abroad, please refer to point 5. Aside from the disclosures described above, we will only disclose your personal data if you have expressly consented, if there is a legal obligation to do so or if this is necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship. In the event of a sale, merger or other reorganisation of some or all of our company's assets, personal information may be transferred, sold or otherwise shared with third parties as part of that transaction or reorganisation. If we provide services before payment, for example in the case of a purchase on account, we may obtain credit information from a credit agency on the basis of mathematical-statistical procedures in order to safeguard our legitimate interests. To this end, we transmit the personal data required for a credit assessment to a credit agency and use the information received on the statistical probability of a default in payment to make a decision on the establishment, execution or termination of the contractual relationship. The creditworthiness report may contain probability values (score values) which have been calculated on the basis of scientifically recognised mathematical-statistical procedures and which include address data, among other things, in their calculation. Your interests worthy of protection are taken into account in accordance with the statutory provisions.

*360yield.com 3lift.com a.rfihub.com addthis.com adnxs.com adscale.de advertising.com amazon-adsystem.com analytics.yahoo.com assets.carforyou.ch bidr.io bidswitch.net casalemedia.com cdglb.com cookiebot.com d.turn.com doubleclick.net dt.adsafeprotected.com everesttech.net google.com ih.adscale.de mathtag.com media.net omnitagjs.com openx.net outbrain.com pixel.adsafeprotected.com pixel.mathtag.com pubmatic.com secure.adnxs.com segment.prod.bidr.io sharethrough.com sslwidget.criteo.com sync.outbrain.com tagger.opecloud.com tpc.googlesyndication.com twiago.com undertone.com www.carforyou.ch www.google-analytics.com www.google.ie yahoo.com

4. Personal Data Processing for Marketing and Analysis Purposes

We and/or our affiliated companies, in particular TX Group companies and AXA (a complete list of the companies concerned can be found here*) aim to continuously improve the digital offers offered to you and to make them more tailored to your needs and more secure. For this purpose, user-specific historical and future data available to us can be continuously linked using various analysis tools, and user behaviour can be analysed, aggregated, pseudonymised and anonymised across all offers. To improve our database, we may use publicly available data or data from third parties. The findings from your use of our services can be used and exploited by other participating companies as part of the analysis of user behavior. Such data processing takes place with pseudonymised or anonymised data. Processing is carried out in particular for the purpose of sending you target group-specific advertising in accordance with point 2 or displaying it on our portals and improving the security of our portals.

*360yield.com 3lift.com a.rfihub.com addthis.com adnxs.com adscale.de advertising.com amazon-adsystem.com analytics.yahoo.com assets.carforyou.ch bidr.io bidswitch.net casalemedia.com cdglb.com cookiebot.com d.turn.com doubleclick.net dt.adsafeprotected.com everesttech.net google.com ih.adscale.de mathtag.com media.net omnitagjs.com openx.net outbrain.com pixel.adsafeprotected.com pixel.mathtag.com pubmatic.com secure.adnxs.com segment.prod.bidr.io sharethrough.com sslwidget.criteo.com sync.outbrain.com tagger.opecloud.com tpc.googlesyndication.com twiago.com undertone.com www.carforyou.ch www.google-analytics.com www.google.ie yahoo.com

5. Transmission of Personal Data Abroad

We are also entitled to transfer your personal data to third-party companies (contracted service providers) abroad if this is appropriate for the data processing described in this privacy policy. These third parties are obligated to comply with data protection to the same extent as us. If the level of data protection in a country does not correspond to that in Switzerland, we contractually ensure that the protection of your personal data corresponds to that in force in Switzerland at all times. We ensure this through one or more of the following measures:

6. Right of Access, Rectification, Erasure or Appeal

You have the right to assert your data protection rights at any time and to request information about whether and which personal data about you is processed by us, how and for what purpose. You can also have your personal data corrected, blocked or deleted at any time with written notification and corresponding proof of your identity to the following address: privacy@carforyou.ch We reserve the right to correspond with you in this context. Please note that even after your request to block or delete your personal data, we will still have to retain some of it within the scope of our legal or contractual storage obligations (e.g. for billing purposes) and in this case will only block your personal data to the extent necessary for this purpose. Furthermore, deletion of your personal data may result in you no longer being able to receive or use the services for which you have registered. Under certain circumstances, you have the right for us to disclose your personal data to you or to a third party designated by you in a common format. You can object to the processing and forwarding of your data for marketing and advertising purposes in accordance with points 2 to 5 at any time by email. Such an objection does not completely exclude the collection of personal data. If you wish to prevent us from collecting your usage data, you can request this by sending an email to privacy@carforyou.ch. The objection merely excludes the possibility that personal data collected may not be processed anonymously for marketing purposes and may thus also be forwarded to other companies and analysed by them. In order to completely exclude or at least reduce the collection of personal data, the steps mentioned in points 9 and 10 regarding the deactivation of cookies must be followed. As a result, you may no longer be able to continue to receive or use the services you have purchased. In addition, you have the right to lodge a complaint with the competent supervisory authority regarding data processing. You can do this by contacting the regulatory authority in your place of residence, workplace or alleged data breach.

7. Retention Period of your Personal Data

We will only store your data for as long as is legally necessary or appropriate to the purpose for which it is processed. For analyses, we store your data until analysis is complete. If we store data on the basis of a contractual relationship with you, this data will be stored for at least as long as the contractual relationship exists and as long as limitation periods for possible claims by us or legal or contractual retention obligations exist.

8. Data Security

We use appropriate technical and organisational security measures to protect your personal data stored with us against unintentional, illegal or unauthorised manipulation, deletion, alteration, access, disclosure or use and against partial or complete loss. Our security measures are continuously being adapted and improved in line with technological developments. We assume no liability for the loss of data or it becoming know to or used by third parties. If you register with us as a user, access to your user account is only possible after entering your personal password. You should always treat payment and access information confidentially and close the browser window when you have finished communicating with us, especially if you share your computer with others. We also take internal data protection very seriously. Our employees and the service companies commissioned by us have been obligated by us to secrecy and compliance with data protection regulations.

9. Cookies

Cookies help make your visit to our websites easier, more pleasant and more effective. Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our website. Cookies will not damage your computer’s hard drive, nor will users’ personal data be sent from these cookies to us. We use cookies, for example, to track who has visited our portal and to determine how often certain pages or offers are visited, which parts of the portal are particularly popular, and in general to determine how the portal is used. We use other cookies so that you can move freely around our portal and use its functionalities, for example when accessing access-protected areas. Such cookies may also be necessary to use shopping baskets or payment functions. By using cookies, you can also use the options or decisions you have selected as settings to make your visit to the portal more convenient. In general, the use of cookies serves to improve our services, making them safer and more effective. However, cookies are also used to collect information in order to offer you advertising that may be of interest to you. Most internet browsers automatically accept cookies. However, you can configure your browser at any time so that no cookies are stored on your computer or a message always appears when you receive a new cookie. In principle, our digital offers can also be used without accepting cookies; however, in this case individual functionalities may be restricted, not properly usable or not usable at all.

10. Tracking and Analysis Tools

The use of our digital services is also measured and evaluated using various technical systems. These measurements can be anonymous or personal. It is possible that the collected data may be passed on to third parties by us or the third party providers of such technical systems for processing. The most frequently used analysis tool is Google Analytics, a service provided by Google Inc. This enables the data collected to be transmitted to a Google server in the USA, whereby the IP addresses are anonymised by means of IP anonymisation so that they cannot be allocated to you. The IP address transmitted by your browser through Google Analytics will not be combined with other data from Google. The collection and processing of this data using Google Analytics can be opposed by setting an opt-out cookie that prevents the future collection of your data when you visit this website. Further information can be found here. You will find further information on the systems we use, in particular on opt-out, at: carforyou.ch

11. Plug-ins and other Integrations of third-party Offers

Our digital services are networked in many ways with third-party functions and systems, for example by integrating plug-ins of third-party social networks such as Facebook or Twitter in particular. Further information and details about the data processing that takes place in connection with these and other plug-ins that we use can be found at: carforyou.ch If you have a user account with these third parties, it may also be possible under certain circumstances for these third parties to measure and evaluate your use of our digital offers. Additional personal data such as IP address, personal browser settings and other parameters may be transmitted to and stored by these third parties. When using a social login service such as Facebook Connect, the provider may provide us with personal information such as your name, email address and profile picture which is stored about you by the provider. We have no control over the use of such personal data collected by third parties and accept no responsibility or liability. We refer to the further information linked above in this context.

12. Legal Principles

We process your personal data only within the framework of the data processing principles and if there is a legal basis. Where it serves to initiate and execute our contract, this legal basis applies. Otherwise, we have an interest in continuously improving our offers, adapting them to your needs and showing you advertisements that might be of interest to you. This is a necessity in order to further develop and finance our offers and to guarantee the security of our offers. We assume that our interests prevail. This applies if you have consented to data processing.

13. Contact Person

If you have any questions regarding data protection on our website, would like to request information or request the deletion of your data, please contact our contact person for data protection law by sending an email to privacy@carforyou.ch. The contact details of our data protection officer are as follows: CAR FOR YOU AG Data Protection Officer Badenerstrasse 567 8048 Zurich Switzerland

14. Timeliness and Changes to Data Protection Regulations

Due to the development of our website or the implementation of new technologies, it may be necessary to change this privacy policy. Registered users and registered contractual partners will be notified of any material changes to the data protection provisions by email to the email address provided during registration or, alternatively, by post to the postal address provided by you during registration or when concluding the contract. You can also call up and print out the current data protection regulations on our website at any time. The original privacy policy is in German. The translated versions are intended solely for better comprehensibility. In the event of disputes, the German text shall prevail. Status: January 2019 Copyright © CAR FOR YOU AG – all rights reserved. Any further processing, republication or permanent storage without our prior express permission is prohibited.

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