Privacy Policy

This Privacy Policy provides information on how Citytransformer Ltd. (hereinafter “CT”, “we”, “us”) collects and processes your “Personal Data” when visiting our website or using our online services.

Personal Data in terms of this Privacy Policy are all information that can be related to you, such as your name, address, e-mail and IP address or your user behaviour.

The following statement gives you an overview about which type of personal data are collected for which purpose and on which legal basis. It also informs you about your rights with regard to us as the controller.

1. Controller

Controller in the meaning of Art. 4 No. 7 EU General Data Protection Regulation (GDPR) is:

Citytransformer Ltd

121 Devora Hanevia st

Tel Aviv

Israel

Telephone number: 972-54-4350592

Fax: 972-77-3179258

If you have any further questions regarding data protection or this Privacy Policy, please contact us at: info@citytransformer.com

2.Data processing on this internet page

Just by merely using this website for information purposes, CT automatically collects and stores information in the server log files which your browser transmits to us. These data are technically necessary in order for us to display this website to you and assure the stability and security of the site:

IP-address,

Region of origin request,

Date, time and duration of the inquiry,

Time difference to Greenwich Mean Time (GMT)

Access status/http status code (file transferred/not transferred),

Content of the request (specific page),

The respectively transmitted data volume,

Website from which the request comes,

Browser, operating system and its graphic user interface,

Language and version of the browser software.

Legal basis for the processing of these data is Art. 6 No. 1 sentence 1 lit. f GDPR.

We will not attribute these data to any specific persons, and these data will not be combined with other data sources. After using you’re the aforementioned personal data for the above purposes, the data will be deleted by us.

3. Contact per e-mail

If you provide us with personal data while requesting certain services, e.g. by sending us an e-mail, as part of an order for products and/or services or other inquiries, we will process your personal data only to perform the requested and rendered services.

The legal basis for this processing is Art. 6 No. 1 sentence 1 lit. b and f GDPR.

4. Collaborations

If you are interested in collaborating with us, you are able to contact us via our collaboration form.

In order to answer you collaboration request we will collect and process the following personal data:

Name,

E-mail address,

Company name,

Job title,

Country,

Your experience in vehicles distribution,

Your representation of other companies in the automotive sector,

Your willingness to consider an LOI for purchase/distribution of CT vehicles as well as you willingness to consider an investment with prioritizes conditions,

Your prediction on the capacity of CT´s distribution.

If you chose to voluntary provide us with further personal data, these data will be collected and processed by us for the above-mentioned purposes as well.

Legal basis for the processing of your personal data is Art. 6 No. 1 sentence 1 lit. b and f GDPR.

5. Pre-Orders

When Pre-ordering a City Transformer Car via our Pre-Ordering form on our website, CT will collect the following personal data in order to process your Pre-Order and to add you to CT´s register of potential customers:

name,
address,
credit card details,
telephone number and
e-mail address.

If you chose to voluntary provide us with further personal data, such as your company´s address etc., these data will be collected and processed by us for the above-mentioned purposes as well.

Any processing of your personal data will serve the sole and exclusive purpose of meeting CT´s contractual obligations related to your Pre-Order. This will also include contacting you via your given contact details in order to inform you about news on the availability of the City Transformer Car in your area as well as refunding your deposit, if applicable.

Legal basis for the processing of your personal data is Art. 6 No. 1 sentence 1 lit. b and f GDPR.

6. Transfer of personal data

We may share your personal data for the purpose stated above with our agents or vendors that provide services for us. If required, we will or already have entered a data processing agreement in accordance with Art. 28 GDPR. Such agents and vendors are contractually prohibited from disclosing confidential information, including any personal data we share with them.

We do not share, sell or lease your personal data to any third parties for their marketing use. We will release information about you only if (i) we have obtained your consent, (ii) are otherwise compelled by law and/or the public authorities to disclose and/or transfer such data, (iii) such transfer is necessary to protect and defend the rights or property of CT or (iv) urgent circumstances warrant such transfer to protect the personal safety of CT employees or the public.

7. Newsletter

You can subscribe to our newsletter via our website. Our newsletter contains information about us and our activities and will be sent to you regularly – usually monthly- by e-mail.

We use the so-called double-opt-in process to register for our newsletter. This means that after your registration we will send you an e-mail to your given e-mail address, in which we will ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 7 days, your information will be blocked and automatically deleted within one month. In addition, we store your IP addresses and times of registration and confirmation in each case. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data. The legal basis for this processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

After your confirmation, we store this data for the purpose of sending you our newsletter. The legal basis for the processing of your personal data is Art. 6 No. 1 sentence 1 lit. a GDPR.

You can revoke your consent to the sending of the newsletter and the associated processing of your personal data described at any time with effect for the future and unsubscribe from the newsletter by clicking on the link provided in each newsletter, by e-mail to info@citytransformer. or by sending a message to the contact details provided in the imprint.

8. Transfer outside the EU/EEA

Since we are globally operating, it is possible that personal data may be processed in third countries outside the EU/EEA and Israel. If data is transferred from the EU/EEA to a third country, we will ensure that the necessary data protection measures are in place, in particular that the requirements of Art. 44 et seq. GDPR are met.

Please find further information on the transfer of personal data outside the EU/EEA, in the context of the use of cookies on this website, in section 9, 11, 12, 13 and 14.

9. Cookies

9.1 General information

When you use our website, cookies are also stored on your computer. Cookies are small text data files which are stored on your hard drive and attributed to the browser you are using and with which the place which sets the cookie (in this case, us) receives certain information. Cookies cannot execute any programs or transfer viruses to your computer. They serve the purpose of making the internet offering in general more user friendly and effective.

You can also prevent the storage of cookies with a corresponding setting in your browser software. If you prevent the storage of cookies, we wish to point out that you may not be able to fully use this website.

9.2 Detailed information on the cookies used on this website

A) Technically necessary cookies

We use so-called technically necessary cookies on our website. Technically necessary cookies are cookies that are necessary for our website to function correctly. They help to make our website usable by enabling basic functions such as page navigation and access to secure areas of the website.

B)Technically not necessary cookies

If you agree, technically not necessary cookies will be used in context with the use of Google Analytics, Google Fonts, YouTube and Social Media Plugins. You will find more detailed information on this in sections 9, 11, 12, 13 and 14.

Analytical cookies collect information about how our website is used, help us optimize the website, and allow us to generate reports about users’ likely interests and likely demographic characteristics. Furthermore, it may be used to provide content that is more relevant to the user and tailored to his or her interests. The latter information may be shared with third parties, such as advertisers.

Web fonts are third-party cookies that we use to provide a consistent look and feel to our website. These are loaded into your browser cache when visiting our website in order to display texts and fonts correctly.

9.3 Legal basis

The legal basis for the use of technically necessary cookies is Art. 6 No. 1 sentence 1 lit. f GDPR.

If you have given your consent to the use of technically not necessary cookies (e.g. for the use of Google Analytics, Google Fonts, Youtube or Social Media Plugins), the legal basis for the use of these cookies is Art. 6 No. 1 sentence 1 lit. a GDPR. Your consent can be revoked at any time with effect for the future by changing your cookie settings

9.4 Additional information for the transfer of personal data outside the EU/EEA

Please note, that your consent to the use of technically not necessary cookies may also include your personal data being processed in the US. For this reason, we would like to inform you in accordance with Art. 49 No. 1 sentence 1 lit. a GDPR, that the US is considered by the European Court of Justice to be a country with no adequate level of data protection according to EU standards. In particular, there is a risk that your data may be processed by US authorities for surveillance and investigation purposes, possibly without the opportunity for legal remedies.

Further information on the transfer of personal data outside the EU/EEA, in the context of the use of cookies on this website can be found in the following sections to Google Analytics, Google Fonts, Youtube and Social Media Plugins.

10. Google Tag Manager

This website uses Google Tag Manager, a solution operated by Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.

Further information on Google Tag Manager´s terms of you can be found at: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/

11. Google Analytics

If you have given your consent, we use Google Analytics to analyze and optimize the use of the website. We use the obtained statistics to improve our offering and design it so that it is more interesting for you as the user. Google Analytics employs so-called “cookies,” text files that are stored in your computer in order to facilitate an analysis of your use of the site. The information about your use of this website produced by the cookie is normally transmitted to and stored on a server of Google in the USA. Recipient of the collected data is Google. In the case of activation of IP anonymization on this website, however, your IP address is first abbreviated within the Member States of the European Union or in other member countries to the Convention on the European Economic Area. The full IP address is only transmitted to and stored on a server of Google in the USA in exceptional situations. At the instruction of the Operator of this website, Google will use this information to analyze your use of the website and compile reports about website activity.

The legal basis for the use of Google Analytics is Art. 6 No. 1 sentence 1 lit. a, Art. 49 No. 1 sentence 1 lit. a GDPR.

You can revoke your consent at any time with effect for the future by preventing the storage of cookies with a corresponding setting in your browser software; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.

You can also prevent the collection of the data produced by the cookie that relates to your use of the website (incl. your IP address) with regard to Google as well as the processing of these data by Google by downloading and installing the browser-Add-on available at the following link: http://tools.google.com/d1page/gaoptout?hl=de. Alternatively to the browser add-on, especially for browsers on mobile devices, you can prevent the collection of your data by clicking on the following link: Opt-Out Cookie. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will have to set the opt-out cookie again. To prevent Google Analytics from collecting data across multiple devices, you must opt-out on all devices.

We use Google Analytics with the expanded “_anonymizeIp()”. This results in IP addresses being further processed in abbreviated form so that a connection to an individual can accordingly be precluded.

In exceptional situations in which personal data are transmitted to the USA, Google transfers and processes your personal data in the US on EU Standard Contractual Clauses as appropriate safeguards for the protection of your personal data within the meaning of Art. 46 No. 2 lit. c GDPR.

Information on the third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, telefax: +353 (1) 436 1001. Terms and Conditions for Use: https://policies.google.com/terms?hl=en, overview of data privacy: https://policies.google.com/?hl=en&gl=de, as well as the data privacy statement: https://policies.google.com/privacy?hl=en&gl=de

12. Google Fonts

We use so-called web fonts provided by Google to ensure a consistent appearance of our website. When visiting our website, necessary web fonts are saved in your browser cache in order to display texts and fonts correctly. For this purpose, your browser has to connect to the Google servers. In doing so, your IP address is transmitted to Google. If your browser does not support web fonts, a standard font from your computer will be used.

Legal basis for the processing is Art. 6 No. 1 sentence 1 lit. a, Art. 49 No. 1 sentence 1 lit. a GDPR.

You can revoke your consent at any time with effect for the future by preventing the storage of cookies through a corresponding setting of your browser software; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.

You can find more information about Google Fonts at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

13. Youtube

We have integrated YouTube videos into our website, which are stored on http://www.YouTube.com and can be played directly from our website. These are all integrated in the “extended data protection mode”, i.e. no data about you as a user will be transmitted to YouTube, if you do not click on the videos to start playing them. Only when you play the videos the data referred to in the next paragraph will be transferred to YouTube. We have no influence on this data transfer.

By visiting the website, YouTube receives the information that you have accessed the corresponding subpage of our website. In addition, the data specified in section 2 of this privacy policy will be transmitted. This is independent of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such evaluation takes place in particular (even for unlogged-in users) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

The legal basis for the use of YouTube is Art. 6 No. 1 sentence 1 lit. a, Art. 49 No. 1 sentence 1 lit. a GDPR.

For more information on the purpose and scope of data collection and processing by YouTube, please refer to the privacy policy. There you will also find further information about your rights and setting options to protect your privacy: https://www.google.com/intl/en/policies/privacy. Transfers to third countries are possible. As an appropriate safeguard standard contractual clauses pursuant to Art. 46 GDPR apply.

14. Social Media Plugin

14.1 Social Plugins

When using our website we allow you to share information with social media sites or to connect with the respective social media site using so-called social plugins. Social networks are able to retrieve personal data, independently of whether you interact with the plugin or not.

For this reason, when we use social plugins on our websites from social networks we integrate them in the following way: When you visit our websites, the social plugins are deactivated, i.e. no data is transmitted to the operators of these networks. If you want to use one of the networks, click on the respective social plugin to establish a direct connection to the server of the respective network. If you are logged onto a social network while visiting our websites with social media plugins embedded in them, the network can collect and store information about such visit and link it to your social media user account. If you want to avoid this, please log out of the network before activating the social plugin. Once you log out, the data retrieved from your visit to our website cannot be combined with the data of your social network user account.

We have no control over the data collected by social media networks through its plugins. We encourage you to read their privacy policies to learn more about the use and function of social media plugins, the categories of data collected, the purposes it is collected for as well as the social networks’ overall data protection practices.

Social plugins of Facebook: Facebook is provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. You will find information on data protection at Facebook here: https://www.facebook.com/policy .

For more information about the processing of your personal data by Twitter, please refer to the Twitter privacy policy at: https://twitter.com/en/privacy.

For more information about the processing of your personal data by Pinterest, please refer to the Pinterest privacy policy at: https://policy.pinterest.com/en/privacy-policy.

For more information about the processing of your personal data by Tumblr, please refer to the Tumblr privacy policy at: https://www.tumblr.com/privacy/en.

In case you choose to share information on social media or if you choose to connect your account with the respective social media site, those social media sites give us automatically access to certain personal data retained by them about you consisting of content viewed by you, content liked by you and information about the advertisements you have been shown or have clicked on.

Further, you can access our website via a third party service, e.g. you can access our website from our social media profiles. In those cases we collect personal data from your social media user account consisting of your first and last name, email address and phone number and any other information you have made public.

We process and use the information specified above for the purposes of improving our website´s features and functionalities, as well as for offering you a personalised service.

Legal basis for the processing is Art. 6 No. 1 sentence 1 lit. a, Art. 49 No. 1 sentence 1 lit. a GDPR.

You can restrict our access to your personal data by changing your privacy settings on the respective social media sites.

14.2 Social Embeds

On our website we provide you with social embeds of the social networks Facebook and Instagram. Social embeds are content from social networks (Facebook and Instagram), which we integrate on our website in such a way that you do not have to leave it. This is called “embedding”. This involves the inclusion of posts, videos or other content from the companies Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; however, personal data may also be processed by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA), Instagram LLC (1601 Willow Road Menlo Park, CA 94025, USA; however, Facebook is responsible for Instagram in terms of data protection, see above), on our website.

You can recognize the social embeds by the respective social media network logos next to an image or post or other content that is recognizable as external. Once these embeds have been activated, you will be able to see the content from each network that we have included on our website.

Before clicking on the respective “Show content” button (“Activation button”), our data protection-friendly activation solution prevents your personal data, such as your IP address, from being transferred to the respective social network. As long as you do not click on the Activation Button to view content, you remain invisible to the operators of the respective social network.

By clicking the Activation Button you agree to the collection of your personal data by the respective network. The respective social network is responsible for the collection and processing of data, including the use of cookies and similar technologies by the social network. Presumably, specifically, information about which of our Internet pages you have visited, and your IP address are then transmitted to the social network, even if you do not have a profile with the respective network or are not logged in there at that time. If you are logged in as a member of the social networks, the network assigns the information to your personal user account. We do not receive any of this information.

Legal basis is for the processing is Art. 6 No. 1 sentence 1 lit. a, Art. 49 No. 1 sentence 1 lit. a GDPR.

We therefore recommend that you read the privacy policy of the respective network before clicking the Activation Button (see section 17).

15. PayPal

We have integrated PayPal components on this website. PayPal is an online payment service provider. Payments are made through virtual private or business accounts. In addition, PayPal allows you to process virtual payments through credit cards, if you do not have a PayPal account. A PayPal account is managed via an email address, which is why there is no classical account number. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also takes on trustee duties and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

Should you use the PayPal payment service, you will be forwarded together with necessary data (e.g. payment amount, recipient of the payment) to PayPal for payment processing.

The legal basis for this is Article 6 No. 1 lit. b) EU GDPR.

Further Information on terms of use and data protection can be found at: https://www.paypal.com/myaccount/privacy/privacyhub

If you do not want to be forwarded, you can choose a different payment method at any time.

16. Retention period

Unless otherwise stated in this Privacy Policy, your personal data will be deleted as soon as these are no longer required for the purposes for which they were collected. If statutory retention periods apply, your personal data will be stored accordingly. The same applies if you revoke your previously given consent to the processing of personal data.

17. Data security

CT takes reasonable technical and organizational precautions to keep all information obtained from our online visitors secure against unauthorized access and use, and we periodically review our security measures.

18. Social media

In addition to this website, you can find us in various social media, currently on Facebook, LinkedIn and Instagram.

For information on the processing of personal data by these social media, please refer to the information under:

Facebook: https://www.facebook.com/privacy/explanation

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Instagram: https://help.instagram.com/519522125107875

19. Links to other websites

This Site may contain “links” to other websites of third parties.

Although we attempt to only link to websites that share our high standards and respect for privacy, we do not monitor or control the information collected when you elect to access a third-party link. The treatment of personal data by the operators of third-party websites may be different from ours. Accordingly, we are not responsible for the content or the data privacy practices employed by other websites.

20. Your rights

According to the GDPR, you have the following rights as a data subject vis-à-vis CT:

Right of access by the data subject (Art. 15 GDPR)

In principle, you have the right to receive information on the points mentioned in Art. 15 GDPR. You also have the right to request a copy of your personal data in accordance with Art. 15 No. 3 GDPR.

Right to rectification (Art. 16 and 17 GDPR)

You have the right to have incorrect personal data corrected. In addition, you have the right to demand that your personal data is deleted if further processing is no longer necessary, if processing is unlawful or if you have withdrawn your consent.

Right to restriction of processing (Art. 18 GDPR)

If the conditions in Art. 18 GDPR are met, you have the right to have the processing of your personal data restricted, i.e. to prevent further processing for the time being.

Right to data portability (Art. 20 GDPR)

Within the limits of Art. 20 GDPR, you have the right to receive your personal data in a machine-readable format in order to forward it or have it forwarded to another controller.

Right to object (Art. 21 GDPR)

If the processing of your personal data is based on Art. 6 No. 1 sentence 1 lit. e or f GDPR, you have the right to object to the processing if the further requirements of Art. 21 GDPR are met.

To exercise these rights or to ask any questions regarding privacy matters, please contact info@citytransformer.com. Exercising your rights is generally free of charge.

In addition, you are entitled to lodge a complaint regarding the handling of your personal data with a supervisory authority.

21. Updates to this Privacy Policy

CT continuously develops and optimizes its services. We may therefore add new features to this website. Should these have any impact on the processing of personal data, we will update this Privacy Policy accordingly.

Last update: September 2021