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PRIVACY POLICY
UAB „Exclusive Luxury Auto“ – the only official representative of Aston Martin and Xpeng brands in Lithuania (hereinafter referred to as “We”, “Company”) values and protects the privacy of personal data, therefore, in this policy (hereinafter referred to as the “Privacy Policy”), we provide you with a detailed description of the way we handle the personal data of individuals (hereinafter referred to as “You” or the “Data Subjects”), when you visit our web site, make an enquiry, sign up for a test drive or a service, buy a car, and in any other manner engage in business with us.
In processing personal data, we comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as the “GDPR”), with the provisions of any other applicable legislation governing the protection of personal data and with the provisions of this Privacy Policy.
In this Privacy Policy, we provide you with the most important structured information about the processing of your personal data, i.e. what personal data we collect, how and why we use it, on what legal grounds we process it, for how long we store it, to whom we transfer it, as well as our obligations in the processing of your personal data, the rights that you have and the means of exercising them.
If you visit our Website, we will assume that you have read this Privacy Policy. If you do not wish to have your personal data processed as described in this Privacy Policy, please do not use the Website and do not provide us with your personal data in any other way.
Attention! From this Website, you may access other pages for which other companies may be the Data controller (Manufacturer or representative offices of other countries), so we always recommend that you consult the Privacy Policy of the page you are browsing to ensure that you are properly informed of the controller’s handling of your personal data.
The Privacy Policy is a constantly evolving document, and we may improve, modify and update it from time to time as necessary, so please visit the Website from time to time to ensure that you are always provided with the most up-to-date version of the Privacy Policy.
The most recent changes to the Privacy Policy have been made and are effective as of 19th September 2025.
TERMS
This Privacy Policy uses the following terms:
- Personal data means any information about an identified or identifiable natural person, or who can be identified, directly or indirectly, by reference to relevant data (e.g. name, surname, email address, vehicle registration number, etc.);
- EEA means the European Economic Area, consisting of the States of the European Union plus Liechtenstein, Iceland and Norway;
- Manufacturers – Aston Martin Lagonda Limited- company registered in the UK (company code 1199255), dataofficer@astonmartin.com; XPeng European Holding B.V., – company registered in Netherlands (company code 81736061), data-privacy@xiaopeng.com;
- Importer- UAB “Autobrava”- company registered in Lithuania (company registration number- 125481247.
- Other terms shall have the meanings ascribed to them and defined in the GDPR.
OUR CONTACTS
The controller of your data UAB „Exclusive Luxury Auto“, company code – 302784148, address: Konstitucijos pr. 21B, LT-08130 Vilnius, email address: info@astonmartinvilnius.lt, info@xpeng.lt phone no. +370649 11118. You can contact our Data Protection Officer at dpo@modus.group.
FROM WHAT SOURCES DO WE OBTAIN YOUR PERSONAL DATA?
We receive your personal data directly from you when you send us enquiries, participate in events we organize, register for test drives, enter into contracts, etc.
The Company also receives information from other sources where permitted by law and where necessary for the purposes of processing your personal data:
- The manufacturers;
- The importer;
- insurance, leasing companies;
- public registers – various publicly available information;
- Internet/communication service providers – when you visit the Website, enter the field of CCTV cameras, etc.;
- other official bodies (e.g. various police departments, tax authorities, DPAI, etc.) – information on investigations.
FOR WHAT PURPOSES AND WHAT PERSONAL DATA DO WE PROCESS?
We process your personal data for the following purposes:
| Purpose– Website administration. Legal basis for processing– consent, Article 6(1)(a) GDPR. Categories of personal data– Information collected by cookies.Full information on the use of cookies and the collection of data using cookies (including the specific cookies used and their retention periods) can be found in the cookie management tool at the bottom of each website. |
| Purpose – Our social media accounts‘ management. Legal basis for processing– Legitimate interest, Article 6(1)(f) GDPR. Categories of personal data– Your comments, feedback and other information you share on our social media accounts.Users of the accounts are subjects to the privacy policy and rules of the social network where the Company’s account is located. We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data:
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| Purpose – Administration of requests made on the website. Legal basis for processing– consent, Article 6(1)(b) GDPR. Categories of personal data – name, surname, email address, telephone number, dealership of your choice, model of car you want, additional information and documents you provide. Data retention period – 2 years after the resolution of your request. |
| Purpose– Customer satisfaction surveys. The Manufacturer monitors and evaluates compliance with the quality standards it has set for customer service, so every time you purchase a service/product from our dealership, the Manufacturer will ask you to complete a customer satisfaction survey to evaluate your experience during the service experience.For more information on the transfer of data to the Manufacturer and its processing of personal data, please refer to the Manufacturers’ Privacy Policy: https://www.astonmartin.com/legal/privacy, https://www.xpeng.com/policy. |
| Purpose – Organizing events. Legal basis for processing– Legitimate interest, Article 6(1)(f) GDPR. Categories of personal data– e-mail address, image if the event is filmed and photographed. Retention period for personal data – 2 years. |
| Purpose – Direct marketing. Legal basis for processing– Consent, Article 6(1)(a) GDPR, Legitimate interest, Article 6(1)(f) GDPR. Categories of personal data– Name, surname, email address, telephone. Data retention period: 3 years or until withdrawal of consent.If you have consented to receive direct marketing communications, your email address and telephone number may be used to send you personalized and general information about goods, services, discounts, offers, competitions, events, news, surveys and other news by email, telephone, text messages and to contact you for these purposes.We may also contact you without your consent if we offer our own similar goods or services or if we ask for your opinion on goods/services you have already purchased. In this case, we will give you the opportunity to unsubscribe from the mailings as a matter of course.You can opt-out of receiving direct marketing communications by clicking on the link at the bottom of each email or at any time by contacting dpo@modus.group. We do not use automated decision-making processes, including profiling, in the processing of your personal data, which may result in legal consequences for you or have similar significant effects. |
| Purpose – Registration for the test drive. Legal basis for processing: performance of the contract, Article 6(1)(b) GDPR. Categories of personal data– e-mail address, name, surname, telephone number, car driven, national ID number, driving license number and issue date. Data retention period – 3 years.Attention! The test drive cars are equipped with a location detection system which is activated in the event of suspected theft, traffic accidents or breaches of the test drive agreement. |
| Purpose – Concluding and executing the sale and purchase agreement. Legal basis for processing: performance of a contract, Article 6(1)(b) GDPR, legal obligation, Article 6(1)(c) GDPR. Categories of personal data – name, surname, address, personal identification number, e-mail address, telephone number, payment data, personal identification document of the buyer and/or representative. If you are buying a car on behalf of a company, we will also ask you to provide documents proving your right to act on behalf of the company. Data retention period – 10 years after the date of completion of the contract. |
| Purpose – Registration to service. Legal basis for processing – performance of a contract, Article 6(1)(b) GDPR, legal obligation, Article 6(1)(c) GDPR. Categories of personal data- e-mail address, name, surname, personal identification number, telephone number, city, date, time, service manager (name, surname), work to be carried out, brief description of the work to be carried out, car body number, registration number, request for a free replacement car or for the pick-up and return of the car, address for the collection and return of the car, services provided (date, services provided, goods purchased, price, quantity), payment details. Data retention period: 10 years after the date of fulfilment of the contract.Attention! If you have Casco insurance, we may collect additional data related to the accident (including the accident declaration, technical passport, etc.) in order to coordinate the estimate of the work and the payment issues with the insurance company. |
| Purpose: Providing data to insurance and/or leasing companies for the preparation and submission of commercial financing and/or insurance proposals. Legal basis for processing: consent, Article 6(1)(a) GDPR. Categories of personal data – name, surname, personal identification number, telephone number, e-mail address, identity document (to verify the identity of the customer). Data retention period – 2 years. |
| Purpose – Opening and extending the manufacturer’s warranty. Legal basis for processing – performance of the contract, Article 6(1)(b) GDPR. Categories of personal data– Vehicle registration certificate, owner’s name, surname, date of registration. Data retention period – 5 years. |
| The purpose- Screen clients for their presence on EU sanctions lists. Legal basis for processing: legal obligation, Article 6(1)(c) GDPR. Categories of personal data: For natural persons: Lithuanian citizens: client’s first name, last name, personal identification number, nationality, phone number, email address, type of identity document, residential address, bank account and the bank from which the payment will be made. EU and EEA citizens: in addition, information is collected on the country where the car will be used, the purpose of purchasing the car, and sanctions screening performed through the engaged service provider. Third-country citizens: in addition, a copy of the residence permit in Lithuania, a copy of the identity document, residential address in Lithuania (certificate of declared place of residence or copy of lease agreement), and a copy of documents proving economic activity in Lithuania are collected.For legal persons: Companies registered in the EU and EEA: extracts from the JAR, JADIS, JANGIS register systems (for companies registered in Lithuania) or information provided in the KYC questionnaire about the persons being verified (client’s manager, board members, council members, representatives, shareholders, ultimate beneficial owners): nationality, first name, last name, legal basis for representation, personal identification number/date of birth, directly/indirectly owned shareholding, country of residence. If any of the persons being verified are not citizens of the Republic of Lithuania, sanctions screening is carried out through the engaged service provider.Data retention period – 8 years. |
| Purpose – Organizing the recruitment process. Legal basis for processing – consent, Article 6(1)(a) GDPR, legitimate interest, Article 6(1)(f) GDPR.Attention! All information on the processing of candidates’ personal data is contained in the candidates’ privacy policy: https://www.modus.group/automotive-candidate-privacy-policy-lt-en. |
| Purpose– Providing video surveillance of our territory and premises to ensure asset protection. The legal basis for processing is legitimate interest, Article 6(1)(f) GDPR. Categories of personal data– image of persons in the field of surveillance cameras. The images are recorded without sound. Data retention period – 30 days. |
| Purpose – Recording calls to ensure the quality of customer service. Legal basis for data retention – legitimate interest, Article 6(1)(f) GDPR. Categories of personal data– call recording. Data retention period – 6 months. |
| Purpose – Debt management. Legal basis for processing – legitimate interest, Article 6(1)(f) GDPR, performance of contract, Article 6(1)(b) GDPR. Categories of personal data– payment data, amount of debt, contact details. Data retention period – until final settlement with us. |
| Purpose – Administration of insured events and claims. Legal basis for processing: performance of a contract, Article 6(1)(b) GDPR, legal obligation, Article 6(1)(c) GDPR. Categories of personal data – car registration certificate, driving license, accident declaration, photographs of the car’s body and registration number, address of the car owner’s and/or driver’s place of residence, telephone number of the owner and/or driver, telephone number of the car, telephone number of the driver, telephone number of the owner and/or driver, telephone number of the driver. No. Data retention period – 10 years. |
WHO DO WE TRANSFER DATA TO?
In certain cases (e.g. to ensure the continuity of our operations, to provide you with services, to comply with legal requirements or to protect our legitimate interests) we may disclose information about you:
- Other Modus Group companies. The Modus Group’s privacy policy is available here: https://www.modus.group/privacypolicy;
- Depending on the brand of car services you have purchased – for the specific manufacturer;
- Importer;
- to our professional advisors, auditors;
- companies providing data center, hosting, cloud, website administration and related services, companies developing, providing, supporting and developing software, companies providing information technology infrastructure services, companies providing communication services;
- companies providing advertising and marketing services;
- leasing companies, brokers and insurance companies, if you express an interest in receiving offers for their services;
- debt collection companies;
- public authorities as provided for by law: the State Tax Inspectorate, the Centre of Registers, the Labor Exchange, etc.;
- law enforcement authorities upon their request or on our initiative if we suspect that a criminal offence has been committed, as well as courts and other dispute resolution authorities; tax authorities.
The list of recipients or categories of recipients specified in the Privacy Policy is subject to change, so if you wish to be informed about changes in the recipients of your personal data or detailed information about specific recipients, please notify us by email to dpo@modus.group, indicating “I would like to be informed of information about the recipients of my personal data, first name, surname”.
TRANSFER OF DATA TO THIRD COUNTRIES
Your personal data will only be transferred to third countries in accordance with the requirements of applicable law.
In each case, if it is necessary to transfer your personal data to a third country or an international organization for the purposes of after-sales service and/or other purposes set out in this Privacy Policy, one of the following conditions shall apply:
- the data is transferred to a country for which an adequacy decision has been made (third countries that meet the required level of protection are approved by the Commission of the European Union);
- the transfer is subject to appropriate safeguards specified by law (e.g. a legally binding and enforceable instrument between public authorities or bodies; rules binding on businesses pursuant to Article 47 of the General Data Protection Regulation; standard data protection terms and conditions adopted by the Commission of the European Union in accordance with the examination procedure referred to in Article 93(2) of the General Data Protection Regulation);
- compliance with other derogations provided for in the legislation, if it is not possible to transfer data in accordance with the above sub-paragraphs.
SECURITY OF PERSONAL DATA
Your personal data will be processed in accordance with the General Data Protection Regulation and other legal requirements. When processing your personal data, we implement organizational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing. These measures include, but are not limited to:
- strict access controls, enforced on a ‘need to know’ basis;
- confidentiality agreements with persons who have access to your data;
- periodic training on data protection and information security;
- documenting and implementing internal data protection procedures;
- appointing a Data Protection Officer;
WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE THEM?
If we process your personal data for the purposes set out in this Privacy Policy, or if you have reason to believe that we are processing your personal data, then you have the following rights as a data subject under GDPR:
- The right to know – to know (be informed) about the processing of your personal data;
- The right of access – to obtain confirmation as to whether your personal data is being processed and, if so, to request access to and a copy of your personal data;
- The right to rectification – to request that inaccurate or incomplete personal data be rectified;
- The right to object – to object to the processing of your personal data;
- The right to withdraw your consent – where we process your data with your consent;
- The right to restrict – to request that the processing of your personal data be restricted for a specific period of time;
- Right to erasure/forgetting – to request the erasure of personal data that is no longer necessary for the purposes for which it was collected or otherwise processed;
- The right to portability – to receive your personal data in a computer-readable format and to transmit those data to another controller;
- The right to complain – to lodge a complaint with the The Data Protection Inspectorate (L. Sapiegos str. 17, LT-10312 Vilnius, email: ada@ada.lt), but we recommend that you contact us first and we will try to resolve all of your requests together with you.
You can exercise your rights by submitting a request to us using the contact details at the top of this Privacy Policy.
At the time of the request, you, as the data subject, must verify your identity in one of the following ways:
- if you are making a request to one of our employees, you must provide a valid proof of identity;
- if you submit your request by post or by courier, you must enclose a copy of a valid identity document, certified in accordance with the procedure established by law;
- if you submit your application electronically, you must authenticate it by electronic means that allow proper identification of the person (e.g. mobile signature, qualified electronic signature, etc.).
Upon receipt of your request regarding the exercise of the rights of data subjects, we will provide you with a reply without delay, but at the latest within 1 month from the date of the request. This period may be extended by a further 1 month if necessary, depending on the complexity and number of requests. You will be informed of such extension in the first month. The information you request will be provided free of charge. However, if we see that your requests are manifestly unfounded or disproportionate, in particular because of their repetitive content, we have the right to charge you a reasonable fee (i.e. to request reimbursement of administrative costs) or to refuse to act on such a request.
A response will be provided in the manner chosen in your request. If you do not specify in your request the method by which you wish to receive the response, the response will be sent to you in the same way as the request was made.
CAN YOU REFUSE TO PROVIDE YOUR PERSONAL DATA AND/OR OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA?
Your personal data is collected and processed in order to provide the Services promptly and appropriately and to respond to your requests, enquiries and complaints as a Customer. If you do not provide your data, if it is incorrectly provided or if you refuse to continue to provide it, we will not be able to respond properly to your enquiries, requests, complaints and/or other requests that require our action.
WHAT IF YOU STILL HAVE QUESTIONS?
For any questions you may have, you may contact us by email at dpo@modus.group or by telephone +37064911116.
END OF PRIVACY POLICY