Introducing our values
Athlon is one of the leading providers of vehicle leasing and fleet management in Europe. Athlon has developed innovative, sustainable and cost-efficient mobility solutions for many years. Our mission is to supply the very best vehicle leasing and mobility solutions to meet our customers' continuously changing needs. Athlon - part of the Daimler group - is headquartered in the Netherlands and present in many other countries. For a complete overview, please visit https://athlon.com/en/business.
Please read this Privacy Statement carefully in order for you to understand how we collect and use your personal data.
You can find the privacy statement of Daimler with the following link: https://www.daimler.com/documents/company/other/daimler-dataprotectionpolicy-fr.pdf
The legal entity responsible for the processing of your personal data, is Athlon Car Lease International B.V., Veluwezoom 4, 1327 AG Almere, the Netherlands.
It might be that for a specific processing of personal data, an affiliate Athlon entity is a joint controller.
If you should have any questions about the processing of your personal data, please contact us using the aforementioned contact details or via email@example.com.
You can also contact Daimlers data protection office at the following address:
Chief Officer Corporate Data Protection
Collection and use of personal data
In this Privacy Statement, we will inform you on the ways in which we collect personal data and for what purposes we use personal data.
Personal data may be obtained from you directly, for example if you opt for using a leased vehicle via our private lease services or if you visit our website. There may also be indirect ways in which we come into the possession of your personal data. If you have received a leased vehicle based upon your employment contract, Athlon may receive information from your employer, such as your contact information. If you have engaged with one of our third party service providers partnering with us in the delivery of our services, we may also receive information from them, such as if maintenance services to your vehicle have been provided.
Based on the service that is provided, you will find information below on the purposes Athlon processes personal data for, which personal data is being processed for each of such purposes, the legal basis for such processing and whom your personal data is being shared with.
Athlon offers various forms of operational lease to commercial markets, such as:
- Operational Service Lease;
- Net Operational Lease;
- Second Drive;
- Short Lease;
- Flex Drive, and
- E-bike and scooter lease
For the provision of operational lease services, we have concluded a contract with your employer. If you would like to use (a form of) operational lease, your employer will share your name, address, city of residence, telephone number and email address with us in order for us to be able to contact you, to create a calculation for your lease vehicle and to provide you with an offer. If you lease a vehicle with Athlon, we also process data about the vehicle (such as license plate number, type and model, fuel type and tax value).
To be able to perform all of the above, we will process your name, address, city of residence, email address (at work), telephone number, lease category, the type, model and service history of your vehicle and operational contact details. In addition, we process information on the management of the vehicle, the vehicle’s condition upon its return to Athlon or any other personal data you have provided us with either through the use of the portal of Athlon or when you call us. The processing of your personal data is necessary for the performance of the contract that Athlon has with your employer. It is in Athlon’s interests to provide you with the best services possible.
We share this information with your employer.
You can contact us by various channels, such as email, telephone and via our website. In this case we will use your personal information to answer your question or request. For this purpose we process your name, contact information, your correspondence with us pertaining to your question or request and all other personal information you provide to us and which is necessary to appropriately respond to you.
Athlon offers private lease to consumer markets.
If you should have any questions about Athlon’s private lease services, you can use our website contact form and fill in your name and contact information. This personal data is used only to answer your question.
You can also request a quote on our website. To be able to accept you as a private lease client, we will collect your personal data. For the purpose of sending you a quote and accompanying preliminary contract, we need to collect your name, address, city of residence, telephone number, email address and date of birth. If you would like to order the vehicle, you should sign the preliminary contract and send it back to us. For the acceptance of the contract, we need you to provide additional personal data to us, such as a copy of your ID (where you have shield your photo identification and social security number), a copy of your payslip and your bank account number. In your country of residence, further relevant information may be needed to evaluate your creditworthiness. For a complete list of such information, please refer to the privacy statement of the Athlon entity of your country of residence.
We have outsourced the evaluation of your creditworthiness to a third party. Athlon does not store this information itself. With this third party we have contractual agreements to ensure that your privacy is protected.
Before acceptance of the contract, it is checked for credit referencing purposes at a local credit registration office, whether you have relevant credit payment deficits. For finding out the credit registration office used for your contract, please refer to the privacy statement of the Athlon entity of your country of residence.
As soon as the acceptance is successful and the contract has been finalized, then we will order your private lease vehicle at the dealer. We exchange only personal data that is necessary to order and deliver the vehicle (telephone number, email address, delivery address or pick-up location). We also record data about the vehicle (license plate number, type and model, fuel and tax value). The processing of your personal data is necessary for the entry into and performance of the contract.
We share your personal data also with a third party with whom we have an agreement for making online payments, such as the deposit payment and the monthly payments of the lease amount. We only share information that is necessary for the execution of the payments.
At the BKR your private lease contract will be registered. If you, during the term of your contract, do not pay or do not fulfil your payment obligations in a timely manner, we are obliged to make a registration with the BKR.
You can contact us by various channels, such as email, telephone and via our website. In this case we will use your personal information to answer your question or request. For this purpose we process your name, contact information, your correspondence with us pertaining to your question or request and all other personal information you provide to us and which is necessary to appropriately respond to you. We may also contact you in relation to your private lease contract.
Athlon provides the following additional services. The processing of your personal data is necessary for the performance of (each of) these contractual services. It is in Athlon’s interests to provide you with the best mobility services possible.
Repair, maintenance and tires
Safety is paramount. It is therefore necessary that regular repair, maintenance and tire services are performed for your vehicle. For purposes of administering your use of the vehicle and to handle the vehicle’s maintenance, we process your name, address, telephone number, email address, lease category, license plate number, type and model and the vehicle’s service history. In addition, you may provide certain information pertaining to vehicle management to us, e.g. your mobile phone number to make an appointment for maintenance services.
Athlon does not perform repairs, maintenance or tire services itself. Athlon uses third party service partners for the provision of such services, such as dealers/garages, body repair shops, maintenance companies and tire-change companies. We share your personal data with our service partners. You may also occasionally directly contact one of our service partners. In that case, you will provide your personal data directly to the service partner. The service partner will then inform us on the work carried out, the cost thereof, your mileage and your name and license plate number.
In case of operational lease, we share information pertaining to maintenance of the vehicle with your employer.
If you experience car trouble along the way, such as a flat tire or other (mechanical) difficulty, Athlon is able to provide roadside assistance. We have contracts with third party service providers, such as specialized breakdown assistance services, towing services or parties that are able to provide a replacement vehicle.
For this purpose we collect the following personal data: your name, email address, telephone number, license plate number and location of where assistance is requested and provided.
We share your information with the third party service providers providing the roadside assistance services.
Damage may occur to your vehicle, either caused by yourself or by a third party. In that case, it may be necessary to handle and repair the damage and arrange for a replacement vehicle to restore mobility. If you experience damage to your vehicle, you are kindly requested to immediately report this to our Driver Desk. In this respect, we process the following information:
- Your name, contact information, license plate number, service history, vehicle details, accident details (including photos of the incident), information on the nature and extent of the damage, information about any other occupants and witnesses and any other relevant information you provide us with in the context of the accident;
- Relevant information of any third parties who are involved in the accident, such as name, insurance company name, insurance policy number and any claims of such third parties;
- Relevant information collected from insurance companies;
- If available: witness statements and/or reports created by the authorities (such as the police).
We share relevant information with insurance companies involved, which may be affiliated and third-party insurance companies.
Athlon occasionally hires a third party expert for determining the damage. We therefore share information with such expert company for the purpose of damage research. The damage report that is created by the expert company, is shared with Athlon. Athlon can also hire other third party professionals, employed on our behalf or on behalf of third parties (such as legal experts and medical experts) if it deems necessary to settle damages or claims or for claim resolution. The reports of these professionals are shared with Athlon.
In case of operational lease, we share information pertaining to accident management with your employer.
Traffic and parking fines management
In principle, being the registered owner of lease vehicles, traffic and/or parking fines incurred by drivers of the lease vehicles will be addressed to Athlon by the competent (foreign) authorities that issue such fines (such as the police or the local municipality).
Athlon provides for timely payment of such fines. Based on the information in our systems, we will charge the imposed fine either to your employer or directly to you. We process your personal data for the purpose of processing and managing the payment of fines and, if applicable, obtaining reimbursement from your employer.
We also process information that we receive from the competent (foreign) authorities: your name, address, license plate number, the nature, place and time of the incident committed and/or the imposed fines.
We need to share this information with your employer, for example if leased vehicles are used in carpools or via CarSharing and Athlon does not know who the actual driver of a specific vehicle is.
The rules on traffic and/or parking incidents may differ per country. Sometimes Athlon is required by law to report only lease driver data to a competent (foreign) authority. The competent (foreign) authority will then turn directly to you for further handling of the traffic and/or parking violations.
Our services include a fuel card program, which allows you to pay for fuel at a gas station.
For the issuance of your fuel card and to administer your fill ups, Athlon collects the following personal data: your name, email address, date of birth, the number of your fuel card, the license plate number of your vehicle, information on the fuel type, mileage and associated costs.
The fuel card is issued and provided to you by a third party. We share your name, address and date of birth with this third party, in order to create the fuel card for you and send the card to you.
Online portals and app
Athlon may offer lease drivers the use of online portals or apps, such as Milo, where information on your leased vehicle, contact information and other personal data has been made easily accessible. Functionality may be added in order for you to report changes, report damage to your vehicle, find records on appointments for repairs, schedule appointments for repairs, maintenance or tire change through online appointment planners, contact our driver desk, pay fines and claim (fuel) expenses.
We will receive your name and email address from your employer in order to enable us to provide you with generated log-in details (username and temporary password) so that you can access our various online portals and apps.
We provide a fully interactive and informative training program called E-Driver. Through the set-up of the training program, E-Driver can be used for analyzing and improving driving behavior and proactively promoting commitment to safe driving, aiming at decreasing accident rates.
We engage third party experts for administering and executing the training program, who will directly contact you or your employer to initiate a safety assessment and provide the actual training program.
For this purpose we share your personal data with third party experts engaged by us to administer and execute the training program. This data has been collected from your employer: your name, email address and license plate number.
We also collect personal data that we receive from the third parties engaged by us: driver risk indexes, trainings recommended, trainings signed up for and trainings completed. This data will be shared by us with your employer.
Athlon offers rental services to commercial markets.
For the provision of rental services, we have concluded a contract with your employer. If you want to use rental services, your employer will share your name, address, city of residence, telephone number and email address with us. We share your personal data with third party rental specialists in order for them to contact you and be able to provide you with an appropriate rental vehicle.
Athlon processes the license plate number of your vehicle, the associated costs, the delivery location, the rental period and company contact person. The processing of your personal data is necessary for the performance of the contract that Athlon has with your employer. It is in Athlon’s interests to provide you with the best services possible. For billing purposes Athlon will share this information with your employer.
You can contact us by various channels, such as email, telephone and via our website. In this case we will use your personal information to answer your question or request. For this purpose we process your name, your contact information, your correspondence with us pertaining to your question or request and all other personal information you provide to us and which is necessary to appropriately respond to you. We may also contact you in relation to our rental services.
We process your personal data in relation to your (potential) purchase of an occasion, the trade in of your vehicle and other related services. This includes the execution of the purchase agreement, the delivery of services and the settlement of the payment transaction.
For this purpose we collect your name, gender, (business) contact information, the name of your company, information related to your trade in vehicle and details needed to complete the purchase transaction, including bank account details. The processing of your personal data is necessary for the entry into and performance of the purchase agreement.
We share your personal data with trade in parties or financial services partners.
You can contact us by various channels, such as email, telephone and via our website. We will collect your personal data when you contact us or if provide additional information in one of our occasion centers, for example, when you send us your question, suggestion, compliment, complaint, or when you request a quote for our services. We can contact you relating to a (potential) purchase of a vehicle.
For this purpose we collect your name, gender, (business) contact information, the name of your company and any other information that you provide to us in the open field entry of the contact form, where you can, for example, pose your question or request.
We process your personal data if we send you periodic surveys to obtain your feedback on our services. For this purpose we process your name, your address, your email address, your license plate number and your interests (as may be indicated by you).
If you would no longer like to receive surveys from us, please contact us via the contact details provided in this Privacy Statement, or unsubscribe via the contact details provided in such survey.
We process your personal data if we send you marketing communication to keep you updated on our events, our special offers and our current and future products and services. For this purpose we process your name, address, telephone number, email address and your interests (as may be provided by you).
If we contact you regarding marketing communication, we will do so either by email or by postal newsletters, brochures and magazines.
We will obtain your consent before using your personal data for purposes other than pertaining to the delivery of our services. We will make it easy for you to indicate if you do not (or no longer) wish to receive our marketing communication, by providing you with an easy opportunity to opt-out before sending any direct email on our products and services, as well as in every direct email we send. You can also contact us via the contact details provided in this Privacy Statement for purposes of unsubscribing. If you opt-out we may still communicate with you via e-mail regarding the delivery of the services.
Athlon collects your personal data if you contact us via our website, for example by means of a contact form or if you send us your question, suggestion, compliment, complaint, or if you request a quote for one of our services.
For this purpose we collect your name, (business) contact information, the name of your company and any other information that you provide to us in the open field entry of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint.
Our websites contain various social media functionalities, such as Facebook, Twitter and LinkedIn buttons, which you may use to share information provided on our websites. Our websites also contains links to our own social media pages, such as our Facebook and LinkedIn pages and our Twitter feed.
For this purpose we process your name, email address, photo, contact list and other information that may be provided by you when using social media functionalities.
Please note, that we are not responsible for the collection and processing of personal data by other companies and organizations, such as social media providers, including the processing of personal data that you disclose to other companies and organizations through or in connection with Athlon’s social media functionalities.
Please, refer to our Cookie statement for information on processing of your personal data via cookies https://www.athlon.com/be-en/cookies.
Personal data of the candidate will be collected and processed, i.e. contact information (name, address, telephone number and email address), employment history, educational background and job specific information. This information is used by Athlon to reply to the candidate’s inquiry, to process the application and to provide the candidate access to other job vacancies. Personal data will be processed and used to select applicants and to match the candidate with potential job vacancies. The email address will be used to ensure proper registration, to contact the candidate during the application process and to facilitate hiring activities. In addition, selected employees of Athlon will be able to access data for administrative purposes.
Athlon will only collect and process special categories of personal data in case this is prescribed and processed in accordance with applicable laws in the country with the respective job vacancy.
In addition to the supply of mandatory data and personal data that the candidate has voluntarily uploaded to the applicant system, additional data can be collected and added to the candidate’s user account. If personal data is being collected which has not been obtained from the candidate directly, it originates e.g. from job agencies and brokers and includes publicly accessible sources.
The provision of personal data is necessary to reply to the candidate’s inquiry and to further process the application and selection and hiring processes. Without the provision of personal data an application cannot be processed.
Recipients of personal data are the parties involved in Athlon’s selection and hiring process. Candidates have the opportunity during the online application process to choose whether to have their data (candidate profile), including their personal data, available for evaluation with respect to other open vacancies.
Other business purposes
Compliance with laws and regulations
Athlon has to be compliant with applicable laws and regulation, including both sectorial recommendations and laws and regulations outside your country of residence.
This implies that it is in Athlon’s interests to process your personal data as appropriate or necessary under applicable laws for purposes of reviewing sanction lists, performing counterparty due diligence, preventing money laundering, financing of terrorism and other (financial) crimes and to respond to requests from public and government authorities, such as supervisory agencies, fiscal authorities and investigative agencies, including public and government authorities outside your country of residence.
Protection of our assets and interests
Athlon would like to protect its own assets and interests. This implies that it is in Athlon’s interests to process your personal data as appropriate or necessary to meet our (internal) client acceptance procedures, to enforce our contractual terms and conditions, to protect our business operations, (intellectual property) rights, safety and property and that of yours or other third parties, to ensure payment of our claims and to allow us to pursue available (legal) remedies or limit the damages that we may sustain.
The personal data that we will process and/or share depends on both the circumstances and on which of the purposes mentioned in the previous paragraphs is applicable. As a principle, Athlon only processes personal data if such is required for one of the purposes mentioned in the previous paragraph.
It is in Athlon’s interests to process personal data for purposes of data analysis, development of new services, enhancement and improvement of existing services, identifying trends and determining effectiveness of our business activities.
For this purpose we process vehicle information and other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph.
Access to Athlon premises
If you visit Athlon’s premises, Athlon may ask you to provide us with personal data for purposes of security and safety. Personal data that are collected for this purpose are your name, contact details and - if relevant - the name of the Athlon employee you would like to visit.
Athlon’s contracting parties
If your personal contact details have been included in the contract between contracting parties, Athlon processes your name, (business) contact information and the name of your company. This is for communication purposes. Athlon’s contracting parties can be e.g. partners, third party service providers, suppliers and customers.
Athlon as a data processor
There are services for which Athlon acts as a data processor on behalf of your employer, such as fleet management services. As the data controller, your employer is responsible for the processing and use of your personal data. In case you should have any questions regarding the processing and protection of your personal data, please contact your employer.
To what parties does Athlon transfer personal data?
Your personal data is treated as confidential and accessed on a need-to-know basis only. We will not share your personal data with third parties, unless such processing is necessary for the provision of our services provided to you and/or your employer.
In addition to what has been stated above on the sharing of personal data as regards each respective service, Athlon will share personal data:
- within the Daimler group, with our affiliates group companies;
- with our third party service partners that we engage for the provision of our services, such as dealers, garages, body repair shops, maintenance companies and tire-change companies;
- with our partner companies involved in the sale and provision of our services;
- with third-party service providers that we engage to perform certain data processing on our behalf, such as in the area of information technology and related infrastructure, security and legal, financial and accounting services.
- with supervisory agencies, fiscal authorities and investigative agencies, if we are required to do so by law
Athlon will use its efforts to ensure that all third parties will comply with applicable laws on data protection.
To the extent that third parties process personal data on Athlon’s behalf and on our instructions, we ensure that technical, organizational and contractual measures have been undertaken in order for your personal data to be exclusively processed for the purposes mentioned in this Privacy Statement. In addition, Athlon will ensure that the respective third party will comply with applicable laws on data protection and will live by the provisions of this Privacy Statement.
Does Athlon transfer personal data to a third country or international organization?
Due to the international nature of our organization and our services, your personal data may be processed in another country than the one you reside in. Athlon will ensure that if your personal data are transferred to another country, adequate technical protection measures will apply, such as through contractual arrangements with third parties.
If personal data is being transferred and processed outside of the EU/EEA, Athlon will have an adequate level of protection in place in accordance with the applicable data protection regulation.
Athlon has implemented several technical and organizational measures to ensure a level of security appropriate to the risks of processing personal data in accordance with applicable data protection legislation.
Athlon has established best practice security measures and requirements for its servers and network components, uses firewalls and encryption. Only authenticated and authorized persons are allowed to use Athlon systems. Locations where data is being stored is accessible to authorized personnel only, using strong authentication.
If you nevertheless become aware of a security breach, we kindly request you to inform Athlon on the shortest possible notice via firstname.lastname@example.org.
How long does Athlon retain personal data?
As a principle, we will retain personal data in accordance with legal and regulatory obligations that apply to Athlon and that contain minimum and maximum retention periods. We will therefore retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by applicable law. Your IP address and the name of your Internet service provider, which we only store for security reasons, will be deleted after seven days.
Legal or regulatory provisions may differ in each country where Athlon is established. Applicable retention periods may also differ based on the type of data processed, the purpose of processing and other factors. For finding out the retention periods applicable to your contract, please refer to the privacy statement of the Athlon entity of your country of residence.
Athlon will implement appropriate measures to ensure that the processing of personal data is performed in compliance with the principle that personal data should not be kept longer than necessary for the purposes for which the personal data are processed
In principle, as a data subject under applicable data protection legislation, you have the right to request Athlon access to, rectification or erasure of your personal data that is being processed. Furthermore, you have the right to restrict processing of your personal data or object to such processing. In case consent has been provided by you to the collecting and further processing of your personal data, your consent may, at any time, be revoked with future effect.
If you would like to exercise any of your legal rights or should have any questions regarding the processing and protection of your personal data recorded in this Privacy Statement, please send an e-mail to the local Athlon entity which is your contractual partner. You can find the contact details in the privacy statement of that respective entity.
If you would no longer like to receive surveys or marketing communication from us, please contact us via the contact details provided in this Privacy Statement, or unsubscribe via the contact details provided in such survey or marketing communication. You also have the right to object, free of charge and at any time, to the processing of your personal data for purposes of marketing, which includes profiling to the extent that this is related to such marketing.
You also have the right to receive your personal data from Athlon in a structured, commonly used and machine-readable format. In addition, you have the right to instruct Athlon to transmit those data to another (specified) company or organization.
In your request to us, please make as clear as possible what personal data your request exactly relates to. We may request you to provide verification of your identity or other evidence before handling and executing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.
Please note that we need to retain certain information for recordkeeping purposes, to comply with other mandatory (minimum) retention periods and/or to complete transactions that began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
Changes to this Privacy Statement
We have the right to change this Privacy Statement unilaterally and at any time. The most recently revised Privacy Statement will be the version that is published on the Athlon website. Any changes to the Privacy Statement will become effective as from the date the revised Privacy Statement has been published on the Athlon website. Your use of the services following these changes means that you have accepted the revised Privacy Statement.
Do you have questions or complaints?
If you should have any questions regarding this Privacy Statement and the processing and protection of your personal data, you are welcome to send an e-mail to email@example.com.
Finally, you have the right to lodge a complaint with the competent supervisory authorities on data protection. For finding out which local supervisory authority is applicable for your contract, please refer to the privacy statement of the Athlon entity of your country of residence.
Athlon - 23th of May 2018