This Policy explains how Bright Box Hungary Korlátolt Felelősségű Társaság (hereinafter - "Bright Box Hungary Kft.")
collects, uses, discloses and otherwise processes personal information about you, when you use its
services and, for these purposes, Bright Box Hungary Kft will be the data controller and will be
processing such data as our data processor.
Bright Box Hungary Kft may also anonymize your personal information so that it can use such anonymous data
to improve its services. For the purposes of anonymizing your data only, Bright Box will be a data
controller and if acting as a processor is responsible for the processing of your personal data by
Bright Box, when acting in its capacity as a data controller but we do have agreements in place to
ensure that Bright Box will not use your personal data for any other purpose.
The information you provide to us through the use of our application or leaving personal data on
website via cookies or filling in the request of information or demo version may then be shared with
other companies within the Bright Box group, including subsidiary companies, affiliates and dealers
Depending on your relationship with Bright Box Hungary Kft, we may also provide or may have already
provided you with other notices about our use of your personal information, for example in relation
to your purchase of a certain model of vehicle or the purchase of other products and/or services on
our website. Those notices, if applicable, are not replaced by this Policy and are therefore still
All the data which may be related to you and may be defined as Personal Data are processed upon
affirmative consent or predominantly, justified interest in direct marketing on our part, as long as
this is carried out in compliance with data protection regulations and competition law regulations.
Responsible authority and contact
Responsible for the processing of your data is:
Bright Box Hungary Kft
Telephone: +36 70 28 59 164
We recommend that you get in touch with our Group Officer for Data Protection for the assertion
of your rights, reporting of data protection incidents and for suggestions and complaints with
regard to the processing of your personal data as well as for the revocation of your consent:
Mr. Alexander Dimchenko: firstname.lastname@example.org
What types of information does Bright Box Hungary Kft collect and why?
- 1.1 When a Dongle is connected to your vehicle, we may collect the following categories of
information (nb – some of these categories will be relevant to post-launch versions of mobile
- 1.1.1 your Vehicle Identification Number, or “VIN” (which is associated with other
information about you) its brand, model and year of manufacture and purchase;
- 1.1.2 details of your vehicle’s general performance, including engine efficiency and health,
mileage, tire pressure, battery status;
- 1.1.3 details of the mobile device to which the Subscription is linked via the App;
- 1.1.4 GPS data to determine the location of you, your vehicle and/or your mobile device,
relative to the location of your vehicle, including the relevant city and country in which each are
located (provided, where required by applicable law, your prior consent has been given, or there is
some other lawful reason to process this personal data);
- 1.1.5. your speed of travel in your vehicle, including average speed, parking duration,
incidents of heavy braking, incidents of rapid acceleration and incidents of exceeding 130km/h;
- 1.1.6 an analysis of the journey undertaken in your Vehicle, including average speed, distance
travelled, parking time, events (such as exceeding any self-set speed limit).
- 1.2 In addition to the above, when using mobile application, Bright Box Hungary Kft may also collect the
following information, in addition to and (where appropriate) in connection with, the above noted
- 1.2.1 your name, date of birth, location and contact details; for example, your address, postal
code, country, telephone numbers and/or e-mail address;
- 1.2.2. the above information (either on its own or in combination with other information we hold
about you) may allow us to identify you as an individual. This type of personal information is
called “personal data”. Where such personal data is collected by App, we will process that
information for the purposes described in this Policy.
- 1.3. NEWSLETTER:
- 1.3.1. When you subscribe to our newsletter in the scope of our online offer. In this case,
Bright Box uses so-called Double Opt-In procedure, e.g. we will first send you a newsletter per
e-mail when you have explicitly confirmed the activation of the newsletter service by clicking a
link in a notification.
- 1.4 Where you contact us in relation to mobile application, requests of information, demo
versions, product presentations, we may also collect the following personal data from you:
- 1.4.1 your name and contact details; for example, your address, postal code, country, telephone
numbers and/or e-mail address;
- 1.4.2 reason for your contact;
- 1.4.3 information about services that interest you;
- 1.4.4 information necessary for legal compliance.
- 1.5 This information will be collected primarily from you but we may also collect it, where
lawful to do so, from and combine it with information which we may already hold about you, from
public sources, third party service providers, government, tax and/or law enforcement agencies, and
other third parties. We may also collect personal data about you from your use of our other Group
- 1.6. COOKIES
Cookies is a small piece of data sent from a website to the user's computer and then stored by
the user's web browser on the user’s computer while the users browsers the website.
- 1.6.1 Management of cookies and types of Cookies
The types or categories of Cookies our website uses is the following:
- absolutely necessary cookies;
- functionality cookies;
- performance and analytical cookies;
- third party cookies;
- social network cookies;
Absolutely necessary cookies
Our website uses absolutely necessary cookies which does not require your consent. This type of
cookies can not be de-activated via the “Privacy settings” on the website, however, you can switch
them off in your browser whenever you want. Please, bear in mind that de-activation absolutely
necessary cookies may affect the website functionality.
Third party cookies
The third party may provide content on various sections of our website. This type of cookies is
called “Third party cookies”. To provide content the vendors or third party must also comply with
applicable data protection and privacy legislation. Furthermore, we work with third parties to
ensure that only necessary information is provided which you have chosen.
Cookies on functionality are used identify your preferences and customize the website upon them.
For these purposes we may collect the following information:
- pages opened;
- topics or rubrics opened;
Analytical and performance cookies
Analytical and performance cookies collect information about how you use our website. This type
of cookies is to provide the efficiency of the website its usability and user-friendliness. If you
disable them we are not able to customize and develop website upon your preferences. For the
purposes of performance analyses we collect the following type of information:
- session duration;
- page views;
- traffic source;
- IP address;
- actions taken (e.g. PDF downloads clicks, form submissions)
Moreover, by saving such types of cookies as sharing our content on particular social media or
transfer from particular social network to our web site we can analyze your preferences and adjust
our social media platforms to you.
Social network cookies
Social network cookies allow you to share your work on social media on your website. We do not
control these cookies, however they are crucial for social media integration, statistics and
customization. Our website uses Google Analytics, a web analytics service provided by Google Inc..
Google Analytics uses so-called "cookies" allowing you to analyze the usage of your website. The
information generated by cookies about the use of the website may be transferred to a Google server
from the US and stored there.
More thorough information about Google Analytics and data protection (inter alia management of
the information sent or to be sent to Google) you can find here.
We may process some information regarding shares on social media when you make it through the
social media tools on our website.
The "cookies" enable the webserver to respond appropriately on your web browser repeated requests
an access because your web browser contains data linking the latter with the webserver. Cookies are
to provide user-friendly services because they store previous user’s preferences.
- 1.6.3. You can customize cookies, delete or refuse all cookies at any time in the settings of
your browser. You can find the relevant information in the help functions of your browser. However,
this can also lead to the fact that you will no longer be able to access certain functions.
For more information regarding the Cookies management please refer the settings of the
Cookies on the Edge - Edge;
Cookies settings in Opera - Opera;
Cookie settings in Safari - Safari;
Cookie settings in Firefox - Firefox;
Cookies in Chrome - Chrome;
Cookie settings in Internet Explorer
- 1.6.4. Cookies’ life
The cookies are stored depending the webserver setting, therefore, their storing period may vary.
The cookies may be stored either for session period or permamently. However, you can easily delete
cookies in the web browser setting.
- 1.7. When you use the Internet, specific information will be automatically transmitted from your
Internet browser and stored by us in so-called log files (Logging).
The log files are saved for malfunctions’ identification and for safety reasons for a short period
time. If a further retention of log files is required for evidence purposes, these logs will be
exempted from deletion until the incident investigation completion.
The following data, may be stored in the log files of the source of access:
- IP address (Internet protocol address) of the end device which was the tool to online access;
- Operating system and information on the Internet browser used, including add-ons (e.g. for the
- Volume of transferred data;
- Internet address of the website (or URL);
- Name of the service provider;
- Name of the retrieved files or information;
- Date, time and duration of the access;
- http status code.
How does Bright Box Hungary Kft use your personal data?
- 2.1 We may use information described in paragraph 1 for the following purposes:
- 2.1.1 to respond to and/or deal with your request or enquiry;
- 2.1.2 to improve the functionality and quality of mobile application;
- 2.1.3 to administer mobile application when you have an active Subscription, which may include
- 22.214.171.124 to book a insurance request, credit request, call-back request, suggestion and complains
request, test drive and/or servicing of your vehicle or (in the case of test drive) a potential
replacement your vehicle, which is then linked to the calendar on your mobile device;
- 126.96.36.199 to enable you to locate nearby car maker or insurance company offices and contact them
via the App;
- 188.8.131.52 to locate your vehicle and/or inform you when your vehicle moves out of a certain
location or is moving when the engine is turned off;
- 184.108.40.206 to enable you to share your location with car maker or third parties (such as roadside
- 220.127.116.11 to enable you to “geo-fence” your vehicle and be notified if your vehicle should travel
outside the “fenced” area;
- 18.104.22.168 to inform you of the health of your vehicle, including issues related to your vehicle’s
engine, tire pressure and battery life;
- 22.214.171.124 to enable you to contact roadside assistance;
- 126.96.36.199 to notify you when your vehicle exceeds any self-set speed limit;
- 188.8.131.52 to analyze any recent trips taken in your vehicle, including notification of when it
travels above a self-set speed limit;
- 184.108.40.206 to enable us to identify whether your contact information has come to us via the App
(rather than another means of contact);
- 220.127.116.11 to satisfy any requests you may make via the App (e.g. a service request);
- 2.1.4 to notify car maker branches of any upcoming services, test drives or other appointments
in relation to you or your vehicle;
- 2.1.5 for internal record keeping;
- 2.1.6 to assist with customer enquiries or complaints in relation to REMOTO, and the development
of new, relevant services;
- 2.1.7 to contact you (directly, either by car maker or by the Group or through a relevant
partner or agent, including Bright Box) by e-mail, text or push notification, for any of the above
reasons (which excludes marketing communications);
- 2.1.8 to carry out direct marketing (either by e-mail, post, phone, text, directly through the
App or via other means);
- 2.1.9 to provide you with information regarding Bright Box, insurance, or car maker special
offers that are generally available to all REMOTO customers with an active Subscription;
- 2.1.10 to inform you of news and updates on Bright Box Hungary Kft policies, car maker, its partner's
and their various product offerings;
- 2.1.11 where necessary as part of any restructuring or sale of Bright Box Hungary Kft, car maker or a
relevant Group company’s business or assets;
- 2.1.12 to perform any contract Bright Box Hungary Kft or any Group Company have with you;
- 2.1.13 for compliance with legal, regulatory and other good governance obligations;
- 2.1.14 for any other purposes related to the management of your legal relationship with car
maker (seller), insurance company, service providers.
Where we are required by applicable law to obtain your prior consent in order to process your
personal data for the purposes described above, we will do so. The above list may be updated from
time to time Bright Box Group’s business needs and legal requirements dictate. In the event that
this Policy is updated, we will provide you with notice of this update as may be required by
- 2.2 Subject to applicable law, we may also process your personal data for other legitimate
business purposes including but not limited to management analysis, audit, forecasts, business
planning and transactions, ensuring our compliance with applicable laws, regulatory requirements
and Bright Box policies, dealing with legal claims and related investigatory and/or administrative
activities and any applicable record retention obligations. We may also process it to establish or
exercise our legal rights and to comply with law enforcement or other government agency requests or
- 2.3 Please be aware that while a Dongle is connected to your vehicle, we may continue to process
some of your personal data for the purposes described above, including when your Subscription has
expired. Therefore, if you no longer wish for Bright Box Hungary Kft to process such Personal Data, please
arrange to have the Dongle disconnected or deactivated by your local car maker office or supplier.
- 2.4 Bright Box Hungary Kft may also convert personal data into anonymous data and use it (normally on an
aggregated statistical basis) for research and analysis to improve REMOTO. For more information,
please see the Aggregated Information section, below.
Aggregated personal information does not personally identify you or any other user of mobile
application. It may be used for statistical analysis and administration, including but not limited
to, analysis of trends, carrying out actuarial work, tailoring products, risk assessment and
analysis of associated costs in relation to the operation of mobile application.
Does Bright Box share personal data with third parties?
- 4.1 Your personal data will be made available for the purposes mentioned above (or as otherwise
notified to you from time to time and where there is a lawful reason to do so, in compliance with
applicable law), not only within Bright Box Group (upon the Binding Corporate Rules) but also with
car maker Group, our third party service providers (upon written agreement).
- 4.2 Mobile Application will also be provided using Microsoft Azure, which is a cloud
based infrastructure hosted by Microsoft as part of their Office 365 offering. Accordingly, in
order to provide you with mobile application, Microsoft will process your personal data for and on
behalf of Bright Box, as our data processor under contract with Bright Box LLC.
- 4.3 If you install the mobile application your personal data may also be made available to
other third parties (within or outside the Group) providing relevant services this list may include
own or third party software developers, providers of support and other services, auditors and/or
compliance managers, IT hosting and/or IT maintenance providers and/or other third party agents.
These companies may use information about you to perform their functions on our behalf. The list of
service providers may vary from region to region, however, your personal information shared within
the framework particular contractual agreements between you and us.
- 4.4 As part of mobile application services, your personal data may be shared with those third
party organizations who assist the dealer or car maker to provide roadside assistance, or roadside
accident/emergency support. Please note that your personal data will only be transferred to these
third parties where their assistance is required, and your personal data will not otherwise be
provided to them as a matter of course. For a full list of the organizations who provide this
support, please refer the dealer whom you purchase your car from.
- 4.5 We may disclose specific information upon lawful request by government authorities, law
enforcement and regulatory authorities where required or permitted by law and/or for tax or other
purposes. Subject to applicable law, personal data may also be released to external parties in
response to legal process, and when required to comply with laws, or to enforce our agreements,
Will your personal data be transfered abroad?
- 5.1 Your personal data may be processed in or accessed from jurisdictions outside the European
Economic Area (“EEA”) by members of the Group or our service providers (such as Microsoft
and Bright Box), which are not based within the EEA. Accordingly, for those individuals with a
connected Dongle and/or using mobile application within Europe, you should be aware that such
recipients of your personal data may be located in countries or territories outside the EEA which
may not have adequate data protection laws equivalent to those within the EEA. In those cases,
steps and robust legal framework will be taken to protect your rights and personal data as required
by applicable law.
- 5.2 Individuals in other regions may also have their personal data transferred outside of their
own country by Bright Box Company. By consenting to the connection of a Dongle, installing the
mobile application, requesting demo version on the webpage, or agreeing to accept Cookies and/or
the activation of a Subscription, and subject to any other requirements of applicable law, this
will also act as your consent to the transfer of your personal data as set out in this Policy.
What choices does Bright Box offer you with regard to direct marketing?
- 6.1 We may wish to provide you with information about new products, services, promotions and
offers from car maker and/or the Group and third parties, which may be of interest to you, and may
invite you to take part in market research or request feedback on services and/or car maker Group
and third party products and services (including but not limited to mobile application). This
communication may occur by post, e-mail, SMS and/or telephone. Where we are required to do so, we
will obtain your prior consent to contact you in this way in accordance with applicable law.
- 6.2 If required by applicable law, we will ensure that any direct marketing or market research
that you receive from us (or when you are contacted by electronic means) will provide a simple
means for you to refuse further marketing from us. For example, in e-mails it may provide you
with an “unsubscribe” link, or an e-mail address to which you can send an opt-out request. We will
take steps to stop any marketing to which you object or in respect of which you withdraw your
consent within a reasonable period, in order to allow sufficient time for the change to be
- 6.3 In such cases, we will not necessarily remove all your personal data from our database(s)
if (for example) retention of your personal data is still required in order to deliver services or
remain aware of your preference not to receive marketing correspondence, which we will note and
respect in any event.
What safeguards are in place to protect your personal data?
- 7.1 Subject to paragraph 7.2 (below), Bright Box takes steps to protect the security of your
personal data in accordance with applicable law. Bright Box and any other data processors acting on
behalf of Bright Box Hungary Kft will be required to implement appropriate technical and organizational
measures to protect the personal data they process against any unauthorized access, alteration,
transmission, public disclosure, deletion or destruction, as well as damage and accidental loss or
deletion of the personal data.
- 7.2 We cannot guarantee the security of any transmission of personal data over the Internet.
Communications over the Internet such as e-mails are not secure unless they have been encrypted.
So, while we strive to protect such information, we cannot ensure or warrant the security of any
information transmitted to us. Please do not submit personal data through the mobile application
or via any our website unless you accept the inherent security risks and implications of using the
What rights do you have to review, amend and/or delete personal data?
- 8.1 You have the right to request certain information about the processing of your personal
data. These rights vary depending on the country you are based in, but generally include (amongst
others) the right to request copies of, access and, in certain circumstances under applicable
laws, oppose the processing of your personal data and/or request the deletion of your personal data
held by Bright Box Hungary Kft and to have certain inaccurate information about you corrected.
- 8.2 If you wish to exercise any of your rights of access, rectification, cancellation and/or
opposition or if you have any questions about this Policy, please contact us using the details set
- 8.3 If you believe that any information we have about you is incorrect or incomplete, please
write to or e-mail us as soon as possible. We will take steps to seek to correct or update any
information as necessary and in accordance with applicable law and pursuant to our checks on
whether that information is in need of correction or update.
- 8.4 All requests to amend, update, delete, access or to obtain copies of your personal data
will be processed in accordance with applicable law.
- 8.5 Where the processing of your personal data is done with your consent, please note you have
the right to withdraw your consent at any time. If you wish to withdraw your consent, please
contact us using the details set out in Annex 1.
Keeping you informed and record retention
Bright Box Hungary Kft may keep your details on record for as long as is necessary for the purposes for
which it may use your personal data, as set out above and as allowed in accordance with applicable
- 10.1 We may change this Policy from time to time by updating this page in order to reflect
changes in the law and/or our privacy practices. We will update the date at the top of the Policy
- 10.2 Where required to do so by applicable law, we will provide notice of any changes. However,
we encourage you to check this Policy for changes whenever you use the App.
- 10.3 Subject to any other requirements of applicable law, by using the Website, submitting your
personal data to us and/or registering an account, you consent to the use and processing of your
personal data as described in this Policy (as amended from time to time).
Right to withdraw consent
At any time you are entitled to withdraw consent to provide personal data. To withdraw consent
you shall either delete the App, or delete profile through mobile app, or request erasure all the
data by e-mail, unsubscribe the newsletter or de-activate dongle via dealership, or erase profile
from the mobile app. Upon withdrawing the consent the Company is obliged to erase the data within
reasonable period of time but not exceeding one month.
If you decide against the receipt of newsletters, you can unsubscribe at any time by revoking
your consent. The revocation of consent does not affect the legality of the data processed until
the revocation. You can withdraw the consent via the link imprinted in the newsletter or in the
administration setting of the respective online offer, if any.
If you have any questions about this Policy, please contact us using the details set out in
This policy may be updated from time to time and you will be notified of any changes by posting
the new version on our website. If you have left us your contact details and authorized us to
contact you, we will notify you if the page is substantially changed. Please refer to this page
periodically to get the latest updates.