IMPORTANT LEGAL NOTICE
This website, iPad Lead Application, Virtual Reality Application, or advertisement on Facebook, as applicable (the "Site", “Website” or “App”) is operated by Cadillac Europe GmbH, a company registered under the Laws of Switzerland and having its registered office at Boulevard Lilienthal 6, 8152 Glattpark, Switzerland ("Cadillac Europe").
The information contained on this Site is designed to be as comprehensive as feasible. We reserve the right (but we will not have an obligation) to make changes at any time and without prior notice to prices, colors, materials, equipment, specifications, models and availability.
Some links provided on this Site may lead to sites furnished by unrelated third party site owners. The information presented therein is the sole responsibility of those site owners. Cadillac Europe has no control over or responsibility for the content of such sites and provides respective links to this Site's visitors for their convenience.
Images shown on this Site may include product details referring to U.S. or Canadian car configurations, which may differ from car configurations available in Europe. The written information contained on this Site is designed to be as comprehensive as feasible for the European market. Please contact your local Sales and Service Partner regarding product availability. You will find the respective contact details on our website under Dealer Locator.
1. TYPES OF DATA BEING PROCESSED / LINKS TO OTHER WEBSITES
Cadillac Europe cares about your privacy. Via this Site, Cadillac Europe does only collect or otherwise process personal data as explained below.
This Site can also contain links to other Cadillac Europe websites or to websites of our affiliated companies, our dealers, authorized repairers or social media websites. When you click on such a link to any of such other websites, please be aware that these websites may have their own data privacy policies. Please check their privacy policies when using these websites.
Please be informed that Cadillac Europe does not accept any responsibility or liability for any third party websites.
2. COLLECTION AND USE OF INFORMATION
For optimizing this Site in terms of system-performance, usability and providing useful information about our products and services, we automatically gather and store information in log files on your computer. This includes your Internet Protocol (IP) address shortened by the last four characters, browser type and language setting, operating system, internet service provider (ISP) and the date/time stamp ("Information").
We use this Information to manage the Site efficiently and upon your consent (via Cookie pop up), learn more about our users’ behaviors across the Site, analyze trends and gather demographic data about our users as a whole. The Information collected may be used upon your specific consent for our marketing and advertising services and communications (for example optimizing and improving the user experience, providing more attractive special offers and services).
If we use non-personal information together with personal data, this information is treated as personal data for as long as it remains combined.
This Site, e-mail messaging, online services, advertisements and interactive applications may use "cookies" for optimizing our services.
What is a "cookie"?
A "cookie" is a small file, typically of letters and numbers that we send to the cookie file of the browser on your computer’s hard disk by our web server. This, for example, allows our Site to recognize a user’s device when a connection has been established between the web server and the web browser. The main purpose of a cookie is to allow our web server to present the user with customized web pages that make the experience when visiting the Site more personal and more responsive to the user’s individual needs.
What kind of cookies does this Site use?
Cadillac Europe may use two types of cookies on this Site:
- Session cookies: these are temporary cookies that are stored in the cookie file of your browser until you end your browser session. Those cookies are mandatory for certain applications or functionalities on this Site to work properly.
- Persistent cookies: we may use persistent cookies for a better user experience (e.g. providing optimized navigation). Those cookies remain in the cookie file of your browser for a longer period. This time period will depend on the choice you make in the settings of your internet browser. Persistent cookies allow information to be passed to a web server each time someone visits the site. Persistent cookies are also known as tracking cookies.
4. THIRD-PARTY COOKIES
5. WEB BEACONS AND PIXELS
This Site contains web beacons (also called: "pixel tags"). A web beacon is an often transparent graphic image, usually no larger than 1 pixel x 1 pixel, that is placed on a website or in an e-mail to monitor the on-line behavior of the user visiting the web site or sending the e-mail. Web beacons are used by third-party technologies, on
this Site those of ["Adobe Analytics"/"Omniture Analytics"/“Omniture Publish”] provided by Adobe Systems Inc.,San Jose, California, United States, to monitor the activity of the visitors to our Site. It allows to track which computer accessed a certain website, when and from where (country/city level).
6. TRACKING AND ANALYSIS
Cadillac Europe uses for a continuous optimization of its marketing communication the analytical software "Google Analytics" by Google LLC, Mountain View, California, United States. It allows for tracking on-line behavior in terms of time, geographic location and usage of this Site. This information is collected via web beacons and/or cookies. The information gained via web beacons and/or cookies is anonymous and will not be connected to personal data. All information that is necessary for this analysis is stored on servers in the United States of America. Cadillac Europe and General Motors Holdings LLC, Detroit, Michigan, U.S.A. ("General Motors") do not share this information with any third party for its independent use.
You can refuse the use of Google Analytics by clicking on the following link. An opt out cookie will be set on the computer, which prevents the future collection of your data when visiting this website: Disable Google Analytics .
Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/ or at https://policies.google.com.
7. ENABLING AND DISABLING COOKIES AND SIMILAR TECHNOLOGIES
You should have the ability to accept or decline all cookies on all the websites you visit by changing the settings in your internet browser. Please refer to your browser instructions to learn more about how to modify your browser settings or how to delete cookies. Please note that certain features and the full functionality of this Site will not be available once cookies are disabled.
In case you want to block third-party cookies (or change your mind later) you can make the appropriate choices on the following website: https://www.adobe.com/privacy.html.
8. DATA PROTECTION
For the purposes of data protection, the data controller is Cadillac Europe GmbH a company registered under the laws of Switzerland. With respect to any questions regarding the protection of your personal data or your rights under the applicable data protection law, please contact our data protection office at firstname.lastname@example.org
9. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our Site. We will use and process such information for fulfilling our obligations in connection with the contract concluded by such registration, or for providing the services subscribed or requested by you. Our legitimization under applicable data protection law will therefore be Art. 6 para. 1 lit. (a) or (b) GDPR. We may keep your personal data for a retention period of 10 years to cover any legal risk of action and claims.
If you contact us, we may keep a record of that correspondence for the time necessary to answer your request and 90 days thereafter. Our legitimization under applicable data protection law is Art. 6 para. 1 lit. (f) GDPR; our reasonable interest in keeping such records is our ability to better answer any subsequent questions you may have. We consider that our legitimate interests abide by the law and the legal rights and freedoms of our users.
We may also ask you to complete surveys that we use for research purposes which, however, regularly will be made on an anonymous basis and otherwise based on consent in accordance with Art. 6 para. 1 lit. (a).
10. IP ADDRESSES AND COOKIES
In some cases, we may collect information about you that is not personally identifiable. Examples of this type of information include your IP address shortened by the last four characters, the type of internet browser you are using, the type of computer operating system you are using, and the domain name of the website from which you linked to our Site or advertisement. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
When you view the Site, we may store some information on your computer. This information will be in the form of a "cookie" or similar file and will help us in many ways. To read more about the types of cookies in use on this site, please read the paragraphs above.
11. PERSONAL DATA AND USE OF YOUR PERSONAL DATA
We will not collect any personally identifiable information about you (that is, your name, address, telephone number, or e-mail address) ("personal data") unless you provide it to us voluntarily. If you do not want your personal data collected, please do not submit it.
We will never sell your personal data. Your personal data will only be disclosed to Cadillac Europe, its affiliated or associated companies, retailers and companies used by Cadillac Europe as subcontractors to fulfill our obligations towards you ("select third parties").
We may ask you for your consent that we may use your personal data to keep you informed about new products, existing, products, services, market research, and special offers, and to measure and improve how we serve you, and we and/or our select third parties may contact you about these by post, telephone, e-mail or text messages/SMS.
If you are an existing customer, we and/or our select third parties might contact you with information relating to the products of General Motors.
If you are a new customer, we and/or our select third parties will contact you only if you have consented to this.
Our Site may, from time to time, contain links to and from the websites of our retailers, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check the respective policies before you submit any personal data to these websites.
We may also disclose your personal data to select third parties in one of the following events:
- In the event that we sell or buy any business or assets we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Cadillac Europe, or all or substantially all of its assets, are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.
- Request from us access to your personal data under Art. 15 GDPR, which right can be exercised by contacting us at the address set out below;
- Request from us rectification or completion of your incorrect or incomplete personal data under Art. 16 GDPR;
- Request from us erasure of your personal data under Art. 17 GDPR;
- Request from us temporary restriction of processing under Art. 18 GDPR;
- Right to data portability under Art. 20 GDPR, i.e. the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly \ used and machine-readable format and the right to transmit those data to another \ controller without hindrance from the controller to which the personal data have \ been provided, where the processing is based on consent pursuant to Art. 6 para. 1 lit. (a), Art. 9 para. 2 lit. (a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. (b) GDPR; and our processing is carried out by automated means.
- Right to object: You have the right to object the processing of personal data concerning you under the conditions specified in Art. 21 GDPR.
- Right to withdraw consent: In so far as processing of personal data is based on Art. 6 para. 1 lit. (a) or Art. 9 para. 2 lit. (a) GDPR, you may withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint: As of 25 May 2018, you can lodge a complaint under Art. 57 para. 1 lit. (f) GDPR with the data protection supervisory authority.
12. WHERE WE STORE YOUR PERSONAL DATA
Your personal data is collected, processed, transferred and used by Cadillac Europe and General Motors and affiliated or associated companies, retailers, agents, suppliers and companies used by Cadillac Europe and/or General Motors as subcontractors to process your request(s) or message(s) as well as for marketing purposes, market research, tracking of sales data and in order to contact you. Your personal data may be transferred and processed outside the European Economic Area (“EEA”) (in particular, for the purpose of storage and processing by the commissioned data processing company in the U.S.). All steps reasonably necessary will be taken to ensure that your data is treated securely and in accordance with applicable laws. Cadillac Europe entered into a bilateral agreement with General Motors on the basis of the EU model clauses “controller to controller “ adapted to
satisfy Swiss law requirements to ensure that General Motors complies with the data protection standards for the transfer of personal data to countries outside of the European Economic Area or Switzerland and will enter into the same or an agreement based on the EU model clauses "controller to processor" adapted to satisfy Swiss law requirements or the trans-border data flow agreement published by the Swiss Federal Data Protection and Information Commissioner, with any other recipients of personal data established in a country outside the EEA and Switzerland.
All information you provide to us is stored on our secure servers located [within the EU/in the U.S.]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
13. CUSTOMER CARE AND ASSISTANCE VIA SOCIAL MEDIA
You may contact Cadillac Europe also via our Social Media Channels (i.e. Facebook, Instagram and Twitter). E.g., if you send us a message or post something on our Social Media Channels, we may use the information in your message or post to follow-up with you on the issue you contacted us for via the Social Media Channel which you used. In order to give you the assistance you requested, we may ask you to provide via direct or private message further information such as details on the issue, name, email, VIN, phone, location (city/state) and/or make, model and year of the vehicle. The information you provide will not be used for direct marketing; market research for service and product improvement will only be carried out on bases of aggregated (anonymized) data.
Please note that you should not include any sensitive data (such as information on racial or ethnic origin, political opinions, religious or philosophical convictions, or health) into you post or message. Be aware that if you post something on a public Social Media Channel, anyone might be able to read it.
15. CONTACTING US
Cadillac Europe GmbH
Boulevard Lilienthal 6
Mail our customer care center: email@example.com
Our Data Protection Officer, who has the primary task of ensuring your rights, monitoring the compliance with GDPR and with the other applicable provisions concerning the protection of personal data, will answer all your questions related to the processing of your personal data and to the exercise of your rights under GDPR.
Our Data Protection Officer can be contacted at the following e-mail address: firstname.lastname@example.org.
You also have the right to contact the data protection supervisory authority in your country of residence. Our DPO can be reached at the following address: FAO GM Europe DPO, 100 New Bridge Street, London, EC4V 6JA, United Kingdom.
GOVERNING LAW AND JURISDICTION
18th of May, 2018
Monitoring & Reporting of real world Co2/ energy consumption data to EU Commission - Regulation (EU) 2021 /392
Involved Region or Country - Europe
EU legislation, Regulation (EU) 2021/392 (“Regulation”) requires Vehicle Manufacturers and Distributors to report real world Co2 and/or energy consumption of vehicles placed into the European market to the European Commission (“EU Commission”).
The EU Commission will use this data to publish annually the average fuel consumption, and the difference between this and the average fuel consumption values recorded in the certificates of conformity for which real world data has been reported by the manufacturer, or responsible agent, for each vehicle type. This data will be aggregated such that It will not be possible to determine the results from an individual vehicle.
Vehicle Co2 and energy data is automatically transferred to GM data servers in USA every time the Techline Connect (TLC)/ Global Diagnostic System (GDS) is connected to the vehicle during any programming or diagnostic event.
Customers have the possibility to “opt out” of their VIN data been used by the EU Commission for the purpose of Monitoring & Reporting of real world Co2/ energy consumption data to EU Commission under the Regulation (see below).
Authorised Repairer MUST inform each customer that their Vehicle Identification Number (VIN) and Co2/energy consumption information will be shared with the EU Commission to meet the obligations of the Regulation.
Authorised Repairer MUST provide customers with a copy of the Processing Notice attached to this bulletin.
“Opt Out” Process when customer is at Authorised Repairer.
Customers may choose to “opt out” and decline that their VIN and Co2/energy consumption information be shared with the EU Commission. In such instances, the GM Authorised Repairer must inform the Customer Assistance Centre ( email@example.com) the VIN of the vehicle that is been requested to “opt out”. Customers can also “opt-out” directly by contacting the Customer Assistance Centre (firstname.lastname@example.org) or our data protection officer at email@example.com.
“Opt Out” Process when customer is NOT at Authorised Repairer.
Customer may also “opt out” after they have visited the Authorised Repairer by contacting our data protection officer at firstname.lastname@example.org.
In these circumstances, please inform the customer to contact the Customer Assistance Centre by email (email@example.com) or our data protection officer at firstname.lastname@example.org, quoting the VIN of the vehicle and requesting that the data should not be reported to the EU Commission.
Processing Notice and option to object against sharing of personal data with the EU Commission – Vehicle Diagnostic Information
General Motors or its affiliates operating in Europe (such responsible affiliate referred to as “GM”, “we”, or “our”) is required to collect and report CO2 emissions data under Regulation (EU) 2021/392 (“Regulation”) to the European Commission (“Commission”). This notice outlines the personal data processing required to comply with the Regulation. The data controller is GM Mobility Europe GmbH, having its registered office at Eschersheimer Landstrasse 14, 60322, Frankfurt am Main, Germany.
The personal data includes vehicle identification number (“VIN”). VIN is combined with vehicle usage and diagnostic data including fuel consumption, energy consumption for vehicles equipped with batteries, and distance travelled. Once reported, the Commission will use this data to measure GM’s real-world emissions performance as required by the Regulation. In doing so, the Commission acts as independent data controller in relation to the reported data.
Our legal basis for processing and sharing this data with the Commission is Article 6 is compliance with a legal obligation per Section (1)(c) of the Regulation (EU) 2016/679 (“GDPR”). We retain this personal data for as long as necessary to satisfy our legal or contractual obligations. We shares this data with its affiliates or service providers to process in accordance with the Regulation. This processing occurs in the EU, Switzerland, United Kingdom, and the United States. We implement standard contractual clauses and other mechanisms, such as appropriate supplementary measures, to provide adequate protection for data transfers.
The Regulation gives you a right to expressly refuse to our sharing this personal data (the VIN number) and the real-world emissions data associated with your vehicle with the Commission. If you refuse after the VIN number and real-world emissions data associated with your vehicle have been shared, your refusal will only apply to future emission data but not to data that has already been shared. You can notify us of your choice to refuse by contacting the GM Customer Assistance Centre at email@example.com or our data protection officer at firstname.lastname@example.org or by writing to: Cadillac/Chevrolet Customer Assistance Centre Box 1062 SE-164 25 Kista Stockholm, Sweden.