PRIVACY POLICY
Last updated: 18 September 2023
What does this policy cover?
This policy describes how Zeekr EU B.V. (also referred to as "Zeekr", "we" or "us") will make use of your data when you interact with us and the Zeekr websites and mobile applications ("Zeekr Platforms"), and when you purchase goods and services from us.
It also describes your data protection rights, including the right to object to some of the processing which Zeekr carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
Personal data we may collect about you
Where we refer to personal data below, we mean any information relating to an identified or identifiable living person.
We may collect and process personal data about you when you interact with us and the Zeekr Platforms, and when you purchase goods and services from us. This includes:
| Category | Details |
Identification and Contact Information | Login & registration information include first name, last name, email address, phone number, account password, login IP and verification code (e.g. to reset your password). |
Delivery Details | Country/state, city, time zone, current time, address, post code. |
Marketing Information | Subscription choice, including email and privacy consents. |
Analytics and Behavioural Information | Your interaction with us including in store, telephone and online interactions (such as signing up to our newsletter, through our Contact Us webform, test drive requests, customer history, call centre interactions and order placements). Your usage of our Zeekr Platforms including browsing habits, the number of pages visited, content viewed, whether or not email communications are opened, which parts of our Zeekr Platforms or email communication are clicked on. For more information about how we use cookies, please read our Cookie Policy. |
Device Information | Device brand, device type, operating system, operating system version, browser, first access source, registration time, language, IP address. |
Order Information | Your purchase details including first name, last name, email address, phone number, ID number, address, invoicing information. |
Payment Information | Confirmation from our third party payment providers in relation to the payment status of your order (including the refund of your deposit), bank account number. |
Financial Service Information | Car configuration and car price, first name, last name, email address, phone number, financing request details (including order number, initial down payment, financing duration/number of instalments, balloon/final payment, included mileage in km per year). |
Test Drive Appointment Information | First name, last name, email address, phone number. If provided by you: your driving history / experience; your postcode; country; showroom location; test drive address; appointment time; preferred car model. |
Car Preference Information | First name, last name, email address, address, preferred car series, preferred car model, preferred purchasing date, preferred purchasing method. |
Car Information | Car licence plate number, Vehicle Identification Number (VIN) and car mileage. |
Voice Recording Information | Recording of your calls with our call centre services team. |
How do we use this information, and what is the legal basis for this use?
We will only use your personal data for the purposes and legal bases set out below:
| Purpose | Legal Basis |
We will collect and use Identification and Contact Information, Order Information, Car Information and Payment Information in order to send you service communications and keep you informed about your order. | Necessary for the performance of our contract with you. |
We will collect and use Identification and Contact Information, Order Information, Payment Information, Analytics and Behavioural Information, Test Drive Appointment Information, Car Preference Information and Car Information in order to provide you with customer service support through our call centre including in relation to car parts enquiries, warranties and refunds. | Necessary in order to take steps at your request prior to entering into our contract with you or as necessary for the performance of our contract with you. |
We will collect and use Voice Recording Information as part of calls with you and our call centre services team in order to ensure quality of service and to improve our services | Your consent where such consent is required and obtained. |
We will collect and use Marketing Information to send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. | Your consent where such consent is required and obtained and otherwise our legitimate interest in promoting our services to our existing customers. If you have asked us to not send you direct marketing, we have a legal obligation to keep a record of this. |
We will collect and analyse your Analytics and Behavioural Information in order to manage and operate our Zeekr Platforms, including to keep it updated and relevant and to develop our business, improve our call centre services and to inform our marketing strategy. | Your consent where such consent is required and obtained and otherwise our legitimate interest in operating our site and improving its operation. |
We will collect and use Identification and Contact Information, Delivery Details, Marketing Information, Analytics and Behavioural Information, Device Information for business purposes such as logging into the website. | Your consent where such consent is required and obtained. |
We will collect and use Identification and Contact Information, Order Information, Car Information and Payment Information to fulfil your request for products and services. (including repair and maintenance services). | Necessary in order to take steps at your request prior to entering into our contract with you or as necessary for the performance of our contract with you. |
We will collect and use your Payment Information to help proceed with your order or request for a deposit refund, an order refund, and monthly payments. | Necessary in order to take steps at your request prior to entering into our contract with you. |
We will collect and use your Financial Service Information to help proceed with your request for a car loan or car leasing. | Necessary in order to take steps at your request prior to entering into our contract with you or if we do not enter into a contract with you our legitimate interest in offering you financing options of third parties at your request. |
We will collect and use Test Drive Appointment Information to confirm your reservation for a test drive appointment and provide you with further service information about your reservation. | Necessary in order to take steps at your request prior to entering into our contract with you. |
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the policy.
How we share your personal data
We share your data with the following categories of recipients:
| Personal Data Category | Category of Recipient | Why? |
Identification and Contact Information, Delivery Details, Marketing Information, Order Information, Analytics and Behavioural Information, Test Drive Appointment Information, Car Preference Information, Car Information and Voice Recording Information | Zeekr group companies | To operate, improve, and develop the Services provided on the Zeekr Platform to you and to provide services outside of the Zeekr Platform such as our call centre services. and repair and maintenance services. |
Identification and Contact Information, Delivery Details, Marketing Information, Analytics and Behavioural Information, Device Information, Order information, Payment Information, Test Drive Appointment Information, Car Preference Information, Car Information and Voice Recording Information | Third party service providers (such as our e-commerce platform in relation to the placement of orders, our sales assistant app which enables the collection of information from you in-store, Salesforce in its provision of customer relationship management services, payment providers in relation to pay the orders; Guance Cloud our cloud hosting provider; and Google Ireland Ltd. and Google LLC for Google services (for details see below)) | We employ other companies and individuals to perform functions on our behalf. Examples include website hosting and maintenance, customer relationship management, identity checking, fulfilling orders for products or services, sending postal mail and e-mails; cloud hosting services; for the Google services see details below. |
Financial Service Information | Third party financial service providers for car loans and car leasing. | Enabling the financial service provider to provide a car loan or car leasing offering at your request. |
Where we transfer your personal data
Personal data that we collect from you may be transferred to and stored at a destination outside the EU/EEA. Due to the global nature of our business, your personal data will be disclosed to service providers outside of the EU and the EEA including, in particular to USA and China, assisting us with hosting and maintenance of the website. Where these locations do not provide an adequate level of data protection, we ensure appropriate safeguards are in place to protect the transfer of your personal data to these countries.
| Category | Mechanism | Country |
As part of Google services: Analytics and Behavioural Information Device Information | EU SCCs | USA (for details see below) |
Maintenance Information | EU SCCs | China |
A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
Google Tag Manager
We use the Google Tag Manager. The provider is Google LLC (“Google”), represented in Europe by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
The Google Tag Manager is a tool that allows us to embed tracking or statistical tools and other technologies on our website. The Google Tag Manager serves to manage and play out the tools integrated via it. The Google Tag Manager records your IP address, which may also be transmitted to Google's parent company in the United States.
The use of the Google Tag Manager is based on your consent pursuant to Art. 6(1)(a) GDPR. You can revoke this at any time with effect for the future in the cookie banner.
The recipient of the data is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google LLC commits to EU Standard Contractual Clauses for the transfer of the data. You should visit Google’s privacy notice to find out more about how Google processes your data.
Google Analytics
This website uses Google Analytics, a web analytics service provided by Google LLC in Europe represented by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland. In this regard, we have concluded a data processing agreement in accordance with Art. 28 GDPR.
Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
IP addresses are shortened or masked as soon as the data is received by Google Analytics and before it is stored or processed. The data is deleted after 2 years.
We only use Google Analytics with your consent pursuant to Art. 6(1)(a) GDPR. You can revoke this at any time with effect for the future in the cookie banner.
The recipient of the data is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google LLC commits to EU Standard Contractual Clauses for the transfer of the data. You should visit Google’s privacy notice for Google Analytics to find out more about how Google uses these cookies and processes your data.
Your choices and rights
You have the following rights:
| Right | Summary |
The right to information | Enables you to receive information regarding whether we are processing your personal data |
The right of access | Enables you to receive a copy of your personal data |
The right to rectification | Enables you to correct any inaccurate or incomplete personal data we hold about you |
The right to erasure | Enables you to ask us to delete your personal data in certain circumstances |
The right to restrict processing | Enables you to ask us to halt the processing of your personal data in certain circumstances |
The right to object | Enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party), including processing for direct marketing purposes - your objection will be upheld, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims that may be brought by or against us |
The right to data portability | Enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible |
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
If you wish to exercise any of these rights, please contact us at the contact details set out below or use the contact form at OneTrust for data subject rights.
Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.
In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
If you have unresolved concerns, you have the right to lodge a complaint to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place. A list of data protection authorities in the EU/EEA is available here. For non-EU countries, please refer to the website of your local data protection authority.
Security
We protect your personal data from loss, misuse, disclosure, alteration, unavailability, unauthorised access and destruction and maintain the confidentiality of your personal data. This is also ensured using appropriate technical and organisational measures. We choose our security measures taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons and continuously improve them.
How long we retain your personal data
We only maintain the personal data we collect for as long as it is necessary for us to provide our services, for as long as it is required to fulfil the purposes of the processing of personal data, or as required by law.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
With regards to the use and retention period of cookies, please read our Cookie Policy.
Updates to this privacy policy
We reserve the right to update this Privacy Policy at any time, and 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 the processing of your personal information.
Contact us
The data controller for your personal data is Zeekr EU B.V., corporate registration number 88529789, with address Jachthavenweg 112, 1081 KJ Amsterdam, the Netherlands.
If you have questions about this Privacy Policy or wish to contact us for any reason in relation to our personal data processing, please contact our data protection officer at dataprivacy@zeekr.eu.