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Privacy & Cookies Policy
Last Updated: November 21, 2018
B2B Tyres is a platform that helps sellers and buyers of the tyre industry to get connected (the “Platform”). The Platform is being managed by B2B Tyres SA with its headquarter in Panama City, in Panama (“B2B Tyres”).
B2B Tyres is committed to doing business with the highest ethical standards by delivering a high-quality Platform to its Users. B2B Tyres is committed to handling information regarding the Users responsibly. In this Privacy Policy, the User can find a description how B2B Tyres handles different types of the User’s Personal Data that are gathered by B2B Tyres.
This Privacy Policy comprises all information related to any operation or set of operations which is performed on the Personal Data or on sets of such data such as collection, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction by B2B Tyres.
B2B Tyres declares that this Privacy Policy is drafted in accordance with the EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the ‘GDPR’).
The declaration above includes information about the type of personal data collected by B2B Tyres via the Platform, as well as the manner in which B2B Tyres uses and processes this data.
Accessing and/or using (creation of the Account included) the Platform implies the User’s informed consent (through disclosure of the User’s Personal Data or opt-in) to the Privacy Policy and consequently to how B2B Tyres collects and further processes the Personal Data.
B2B Tyres takes responsibility for the processing of the User’s Personal Data as the Processor and the Controller. Taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, B2B Tyres declares to implement appropriate technical and organizational measures for ensuring that, by default, only the Personal Data which are necessary for each specific purpose of the processing are processed and to be able to demonstrate that such processing is performed in accordance with the GDRP.
This Privacy Policy is applicable to the Platform and any other relations between B2B Tyres and the User.
This Privacy Policy may be revised or updated by B2B Tyres anytime. The User will be notified about any modification, no later than at the date of the revision or the update of the Privacy Policy, by posting appropriate notice and by an email. If the User disagrees with the revised Privacy Policy, the User shall delete his/her Account. If the Account is not deleted before the date the revised Privacy Policy becomes effective and the User continues the access to and/or the use of the Platform, the User will be the subject to the revised Privacy Policy.
The following terms used in this Privacy Policy shall have the meaning ascribed to them below:
Account
refers to a set of resources and rights within a given computer system assigned to you as the User for the purpose of accessing and/or using the Platform.
B2B Tyres
refers to B2B Tyres SA with its headquarter in Panama City, Panama.
Buyer
refers to a User who buys tyres or other related products to be announced in the Platform as set out in this Privacy Policy and the Terms of Use.
Cookie
refers to a small data file that B2B Tyres transfers to the User’s device hard disk for record-keeping purposes. B2B Tyres uses Cookies on the Platform to help analyze its web page flow; customize B2B Tyres’s services, content and advertising; measure promotional effectiveness, and promote trust and safety.
Controller
refers to an entity (here B2B Tyres) which determines the purposes and means of the processing of the Personal Data.
GDPR
refers to the Regulation 2016/679 of The European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
refers to an American online social media and social networking service company (Facebook, Inc.) based in Menlo Park, California.
Observer
refers to any person entering the Platform without creating an Account.
Personal Data
refers to all data mentioned in the section Collection Of Personal Data by B2B Tyres).
Privacy Policy
refers to this document concerning provisions related to Privacy and Cookies Policy.
Privacy Rights
refers to your rights concerning your Personal Data.
Processor
refers to an entity (here B2B Tyres) which processes the Personal Data on behalf of the Controller.
Seller
refers to a User who sells tyres or other related products to be announced in the Platform as set out in this Privacy Policy and the Terms of Use.
User
refers to a person acting as a buyer or a seller who accesses and uses the Platform via the User’s Account.
User Content
refers to any content and information posted, uploaded, published, linked to, transmitted, recorded, displayed or otherwise made available on the Platform and/or transmitted by a User to other Users, including text messages, chats, videos, photographs and others whether it is publicly or privately transmitted.
The headlines of sections have been placed only for convenience and will not affect the interpretation of the relevant provisions of this Privacy Policy.
Unless it is clear from the context, expressions in the singular form shall include the plural form and vice versa.
All references to legal provisions refer to the content of the applicable law (including all amendments, supplements and amendments adopted at that time).
3.1 Information B2B Tyres collects
IP address of the User’s device
3.2 Information the User gives to B2B Tyres
Account Information – being the User’s first and last name, email address and address;
Profile and Listing Information (needed for transaction and creating a listing) – the User’s address, phone number and a profile picture.
Identity Verification Information (helps to create and maintain a trusted environment) – images of the User’s government issued ID and/or passport, national ID card, driving license as permitted by applicable laws or other authentication information;
Payment Information (needed for transactions and creating a listing to facilitate the processing of payments): the User’s bank account or credit card information. For this B2B Tyres uses a third party payment provider. As such the Payment Information is not visible for B2B Tyres;
Communications with B2B Tyres and other Members – information about the User’s communication (such as history of correspondence) and any information the User chooses to provide.
The User may choose, but the User is not obliged, to provide B2B Tyres with additional personal information in order to obtain a better User’s experience when using the Platform.
Additional Profile Information (some of this information as indicated in the Account settings is a part of the User’s public profile page and it is publicly visible to others) – city where the User is from, personal description;
Other Information – information provided when filling in a form, conducting a search, updating or adding information to the User’s Account, responding to survey, posting to community forums, participating in promotions or using other features of the Platform,
Payment Information – the User’s bank account or credit card information in order to process payments and comply with applicable law when the User makes a transaction or accepts a transaction;
Identity Verification and Other Information – images of the User’s government issued ID and/or passport, national ID card, driving license as permitted by applicable laws or other authentication information, the User’s date of birth, the User’s address, the User’s email address, the User’s phone number and other information in order to verify the User’s identity by B2B Tyres’s payment partners.
3.3 Information automatically collected by B2B Tyres
3.4 Information that B2B Tyres collects from third parties
B2B Tyres does not control, supervise or respond or how the third parties process the User’s Personal Data and any information request regarding the disclosure of such data to B2B Tyres shall be directed to such third parties.
The Personal Data are provided to B2B Tyres therefore expressly and voluntarily by the User.
The Personal Data can be obtained by B2B Tyres by:
Data obtained by B2B Tyres by placing Cookies in the Observer or the User device are not used to identify the Observer or the User through these data, but to allow B2B Tyres to draw up statistics regarding the use of the Platform.
The User is responsible for ensuring the accuracy of the Personal Data submitted to the Platform. Inaccurate information will affect the User’s ability to access the Platform and B2B Tyres’s ability to contact the User as described in this Privacy Policy.
B2B Tyres uses, stores, and processes information, including personal information, about the User to provide, understand, improve, and develop the Platform, create and maintain a trusted and safer environment and comply with B2B Tyres’s legal obligations.
B2B Tyres will not, without the User’s express consent, provide the User’s Personal Data to any third parties for the purpose of direct marketing.
B2B Tyres collects and processes the User’s Personal Data in order to:
to enable the User to access and use the Platform;
to enable the User to communicate with other Users;
to operate, protect, improve and optimize the Platform and experience such as by performing analytics and conducting research;
to provide customer service;
to send the User service or support messages, updates, security alerts and account notifications;
to facilitate the User’s referral invitations,
to send User’s requests for references,
to provide fraud detection and prevention;
to provide any other services authorized by the User at the time of collection of the Personal Data;
to operate, protect, improve and optimize the Platform and experience and personalize and customize the User’s experience (such as making listing suggestions or ranking search results) – B2B Tyres conducts profiling base on the User’s interaction with B2B Tyres, the User’s search and transaction history, the User’s profile information and preferences, and other User Content submitted to B2B Tyres
B2B Tyres processes this information given its legitimate interest in improving the Platform and the Users’ experience with it, and where it is necessary for the adequate performance of the contract with the User.
to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity;
to conduct security investigations and risk assessments;
to verify or authenticate information provided by the;
to conduct checks against databases and other information sources;
to comply with B2B Tyres’s legal obligations;
to resolve any disputes with any of the Users and enforce B2B Tyres’s agreements with third parties;
to enforce B2B Tyres’s Terms of Use and other policies;
in connection with the activities above, B2B Tyres may conduct profiling based on the User’s interactions with the Platform, the User’s profile information and other content the User submits to the Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Platform if such processes detect the User or activity that B2B Tyres think poses a safety or other risk to B2B Tyres, other Users, or third parties.
B2B Tyres processes this information given its legitimate interest in protecting B2B Tyres, to measure the adequate performance of B2B Tyres’s contract with the User, and to comply with applicable laws.
to send the User promotional messages, marketing, advertising, and other information that may be of interest to the User based on his/her preferences (including information about B2B Tyres or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google);
to personalize, measure, and improve B2B Tyres’s advertising;
to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by B2B Tyres or its third-party partners;
to conduct profiling on the User’s characteristics and preferences (based on the information the User provides to B2B Tyres, the User’s interactions with the Platform and B2B Tyres, information obtained from third parties, and the User’s search and transaction history) to send the User promotional messages, marketing, advertising and other information that B2B Tyres thinks may be of interest to the User.
B2B Tyres will process the User’s Personal Data for the purposes listed in this section given its legitimate interest in undertaking marketing activities to offer the User products or services that may be of the User’s interest. The User can opt-out of receiving marketing communications from B2B Tyres by following the unsubscribe instructions included in B2B Tyres’s marketing communications.
to detect and prevent fraud, abuse, security incidents, and other harmful activity;
to conduct security investigations and risk assessments;
to conduct checks against databases and other information sources;
to comply with legal obligations (such as anti-money laundering regulations);
with the User’s consent, to send the User promotional messages, marketing, advertising, and other information that may be of interest to the User based on his/her preferences.
B2B Tyres processes this information given its legitimate interest in improving the Users’ experience, and where it is necessary for the adequate performance of the contract with the User and to comply with applicable laws.
To exercise the User’s Privacy Rights, the User shall contact B2B Tyres via its email privacy at info@b2btyres.com
In connection with the Personal Data, the User has following Privacy Rights:
Exercising of the Privacy Rights is free of charge. The User is always allowed, via the User’s Account, to update, modify and/or verify the User’s Personal Data.
B2B Tyres declares to storage and process the Personal Data within the European Union, Asia Pacific and North America. Laws in these countries may differ from the laws applicable to the User‘s country of residence. As such, B2B Tyres developed binding corporate rules to handle the data transfers occurring within the company.
B2B Tyres stores and processes the Personal Data during the period necessary depending on the purposes of the processing of the Personal Data described in this Privacy Policy. It means the User’s Personal Data will be kept by B2B Tyres as long as it is reasonably necessary taking into consideration our need to answer queries or resolve problems, provide improved and new services and comply with legal requirements under applicable law(s). This means that B2B Tyres may retain the Personal Data for a reasonable period after the User stops using the Service provided by B2B Tyres. After this period, the User’s personal information will be deleted from all systems within B2B Tyres.
Any transfer of the Personal Data outside the European Economic Area (EEA) to a recipient whose domicile or registered office is in a country which does not fall under the adequacy decision enacted by the European Commission, shall be governed by the provisions of a data transfer agreement, which shall contain (i) the standard contractual clauses, as referred to in the ‘European Commission decision of 5 February 2010 (Decision 2010/87/EC)’, or (ii) any other mechanism pursuant to privacy legislation, or any other regulations pertaining to the processing of personal data.
The processing of the Personal Data may include profiling.
7.1 Disclosure to business partners
B2B Tyres has the right to disclose some of the Personal Data to its business partners for the performance or delivery of the services offered by B2B Tyres.
Without prejudice to the foregoing, B2B Tyres shall not disclose any of Personal Data (apart from the Personal Data visible on the site or Platform) to any third parties for indirect marketing purposes without the consent of the User.
7.2 Sharing between Users
To help facilitate interactions between Users, B2B Tyres may need to share certain information, including Personal Data, with other Users.
7.3 Profiles, Listings, and other Public Information
B2B Tyres lets the User publish information, including personal information that is visible to the general public. For example:
Based on B2B Tyres’s legitimate interest to promote the Platform, B2B Tyres may display parts of the Platform (e.g., the User’s listing page) on sites operated by B2B Tyres’s business partners, using technologies such as widgets or APIs. If the User’s listings are displayed on a partner’s site, information from the User’s public profile page may also be displayed.
Information the User shares publicly on the Platform may be indexed through third party search engines. In some cases, the User may opt-out of this feature in the Account settings. If the User changes the settings or his/her public-facing content, these search engines may not update the Users’ databases. B2B Tyres does not control the practices of third party search engines, and they may use caches containing the User’s outdated information.
7.4 Service Providers
B2B Tyres uses a variety of third-party service providers to help B2B Tyres provide services. Service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help B2B Tyres to: (i) verify the User‘s identity or authenticate the User‘s identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of B2B Tyres‘s services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to the User‘s Personal Data to perform these tasks on B2B Tyres‘s behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.
B2B Tyres will need to share the User‘s information, including Personal Data, in order to ensure the adequate performance of B2B Tyres‘s contract with the User.
7.5 Social Media Platforms
Where permissible according to applicable law B2B Tyres may use certain limited personal information about the User, such as the User‘s email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to the Platform or otherwise promote B2B Tyres‘s products and services or the Platform. These processing activities are based on B2B Tyres’s legitimate interest in undertaking marketing activities to offer the User products or services that may be if the User‘s interest.
The social media platforms with which B2B Tyres may share the User’s Personal Data are not controlled or supervised by B2B Tyres. Therefore, any questions regarding how the User‘s social media platform service provider processes his/her Personal Data should be directed to such provider.
7.6 Aggregated Data
B2B Tyres may also share aggregated information (information about the Users that B2B Tyres combines together so that it no longer identifies or references an individual User) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
7.7. Exceptions
Except for the situation described above, B2B Tyres shall not disclose any of the Personal Data to third parties unless it is necessary in the context of providing proper functionality of the Platform and optimizing it. If it is necessary that B2B Tyres discloses the Personal Data to third parties in this context, the third party is required to use the Personal Data according to the provisions of this Privacy Policy.
Notwithstanding the foregoing, it is, however, possible that B2B Tyres discloses the Personal Data:
B2B Tyres declares to take all appropriate technical and organizational measures to protect the confidentiality and security of the Personal Data. These efforts include, but are not necessarily limited to: (i) storing the User’s personal information in secure operating environments that are not available to the public and that are only accessible by persons authorized by B2B Tyres and, (ii) verifying the identities of the Users before they can access the Personal Data B2B Tyres maintains about them.
In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, B2B Tyres will notify the User if the breach is likely to affect the User’s privacy.
The User is obliged to comply with safety standards, for instance by avoiding all non-authorized access to the User’s devices and the Account. The User is solely responsible for the use of the Platform on the User’s devices, IP-address and identification data, as well as for its confidentiality.
Notwithstanding the security measures and policy adopted by B2B Tyres, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the Internet or any method of electronic storage is 100% secure, B2B Tyres does not guarantee absolute security.
B2B Tyres informs to use Cookies to distinguish the Users’ preferences and to offer better functionality of the Platform.
At the moment of the first access to the Service, the User accepts different kinds of Cookies used by the Platform. Otherwise (in case of the lack of such acceptance), the User shall delete his/her Account.
The User can block Cookies by activating the User’s browser settings which allow the User to refuse the Cookies. The rejection of these Cookies may have the effect of not allowing the User to use some functionalities of the Service Platform.
More information on Cookies can be found via the following link: http://www.allaboutcookies.org/
B2B Tyres uses session cookies (which expire once the User logs out from the Account) and persistent cookies (which stay on the User’s device for a set period of time or until the User delete them). The following types of cookies are used by B2B Tyres for the purposes explained in this overview:
TYPE OF COOKIES: Strictly necessary Cookies
PURPOSE: Providing a possibility to use the Platform or providing certain functions the User requested.
TYPE OF COOKIES: Functionality Cookies
PURPOSE: Improvement of the functionality of the Platform.
TYPE OF COOKIES: Tracking Cookies
PURPOSE: Capturing of the User’s traffic behaviour. This type of Cookies survives the User’s session. When the max-age of a permanent cookie is set at one year, then, within that year, the initial value – stored in that Cookie – shall be sent back to the server each time the User visits the server – the purpose is to save a vital piece of information, such as how the User initially came to the App.”
TYPE OF COOKIES: Performance Cookies
PURPOSE: Improvement the functionality of the Platform. The Platform uses Cookies connected with Google Analytics to analyze how the Users use the Platform. It records the number of visitors and it provides B2B Tyres with information on their overall behaviour – such as the typical duration of a visit to the Platform or the number of pages a user views on average. “
The Platform may contain electronic images known as Web beacons (sometimes called single-pixel gifs). Web beacons are used along with Cookies to compile aggregated statistics to analyze how the Platform is used and may be used in some of B2B Tyres’s emails to let B2B Tyres know which emails and links have been opened by recipients. This allows B2B Tyres to gauge the effectiveness of its customer communications and marketing campaigns.
If there are any questions about B2B Tyres’s Privacy Policy and how it relates to the User’s use of the Platform, the User can contact B2B Tyres at info@b2btyre.com
11.1 Use of the Platform
The User’s Account can be created only by a person who is at least 18 years-old.
11.2 Liability for User Content
B2B Tyres is not liable for any User Content.
11.3 Third Party Partners & Integrations
B2B Tyres is not liable for any links that may be found in the Platform, which lead and/or allow the User to directly enter any third party websites, nor for any potential Personal Data protection infringements that could occur in connection with browsing such websites. Because of that the User shall acknowledge any privacy provisions which may be found on such third party websites.
11.4 Google Maps/Google Earth
Parts of the Platform use Google Maps services, including the Google Maps API(s). Use of Google Maps is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.
11.5 Analyzing the User’s Communications
B2B Tyres may review, scan, or analyze the User’s communications on the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development and customer support purposes. For example, as part of B2B Tyres’s fraud prevention efforts, B2B Tyres scans and analyzes messages to mask contact information and references to other websites. In some cases, B2B Tyres may also scan, review, or analyze messages to debug, improve, and expand product offerings. B2B Tyres uses automated methods where reasonably possible. However, occasionally B2B Tyres may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. B2B Tyres will not review, scan, or analyze the User’s communications to send third party marketing messages to the User, and B2B Tyres will not sell reviews or analyses of these communications. These activities are carried out based on B2B Tyres’s legitimate interest in ensuring compliance with applicable laws and B2B Tyres’s Terms of Use, preventing fraud, promoting safety, and improving and ensuring the adequate performance of B2B Tyres’s services.
11.6 Entry into force
This Privacy Policy enters into force on November 21, 2018