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 in effect.
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
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
Responsible for the processing of your data is:
Bright Box Hungary Kft
Telephone: +36 70 28 59 164
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 application):
- 1.1.1 yyour 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
- 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 company services.
- 1.6. COOKIES
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 (amongst others):
- 188.8.131.52 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;
- 184.108.40.206 to enable you to locate nearby car maker or insurance company offices and
contact them via the App;
- 220.127.116.11 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;
- 18.104.22.168 to enable you to share your location with car maker or third parties
(such as roadside assistance);
- 22.214.171.124 to enable you to “geo-fence” your vehicle and be notified if your vehicle
should travel outside the “fenced” area;
- 126.96.36.199 to inform you of the health of your vehicle, including issues related to
your vehicle’s engine, tire pressure and battery life;
- 188.8.131.52 to enable you to contact roadside assistance;
- 184.108.40.206 to notify you when your vehicle exceeds any self-set speed limit;
- 220.127.116.11 to analyze any recent trips taken in your vehicle, including notification
of when it travels above a self-set speed limit;
- 18.104.22.168 to enable us to identify whether your contact information has come to us
via the App (rather than another means of contact);
- 22.214.171.124 11 to satisfy any requests you may make via the App (e.g. a service
- 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
- 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 applicable law.
- 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 court orders.
- 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, corporate policies, and/or
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
- 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 administered.
- 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
- 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 Internet.
What rights do you have to review, amend and/or delete personal
- 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 out in
- 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 law.
- 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 accordingly.
- 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 herein.
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