Privacy Policy

KW Auto, Klintberg & Way Automotive SA, a company incorporated under Swiss law, with registered office at:

c/o Fidinam SA
Via Maggio 1
6900 Lugano
Switzerland

Registered with the Commercial Register under number CHE-287.970.539 (“KW Auto” or the “Controller”).

Operational office: Via G. Pioda 9, 6900 Lugano, Switzerland

This Privacy Policy governs the processing of personal data collected through:

• the Sales Portal
• embedded vehicle configurators on dealer websites
• lead generation forms connected to the platform

• Identification data (first name, last name)
• Contact data (email, phone)
• Professional data (company, role)
• Vehicle-related data (model, configuration, purchase intent)
• Technical data (IP address, browser, device)
• Usage data (navigation, interaction)
• Marketing data (cookies, tracking technologies, CRM data)

• lead generation and management
• assignment and distribution of leads to dealers
• customer contact and follow-up
• dealer network coordination
• analytics and performance monitoring
• marketing communications (with consent)
• IT security and fraud prevention

• Lead generation and handling: Art. 6(1)(b) GDPR (pre-contractual measures requested by the user)
• Lead distribution to dealers: Art. 6(1)(f) GDPR (legitimate interest)
• Customer follow-up by dealers: Art. 6(1)(b) GDPR (pre-contractual measures)
• Marketing communications: Art. 6(1)(a) GDPR (consent)
• Analytics and performance monitoring: Art. 6(1)(f) GDPR (legitimate interest)

Legitimate Interest Assessment

KW Auto has a legitimate interest in ensuring that user requests are handled efficiently by assigning leads to the most relevant authorized dealer based on geographic location or user preference. Personal data is only shared with authorized dealers and used strictly for responding to the user's request. A documented Legitimate Interest Assessment (LIA) has been conducted to ensure necessity and proportionality.

KW Auto acts as Data Controller for the collection and initial processing of personal data through the Sales Portal. Personal data will be securely shared, without undue delay, with one of our authorized dealers — selected based on geographic location or user preference — for the purpose of directly contacting the user.

Upon receiving the lead, the dealer acts as an independent Data Controller for customer contact, follow-up and sales activities. KW Auto and the dealer are not intended to act as joint controllers within the meaning of Article 26 GDPR.

• dealer network
• PK Solution
• CRM and marketing platforms (e.g. HubSpot or equivalent)
• Advertising platforms (including Meta Platforms Inc. and Google LLC)

Personal data may be transferred to providers outside the EEA, including:

• Google LLC (analytics and advertising services)
• Meta Platforms Inc. (advertising services)

Transfers are safeguarded via the EU-US Data Privacy Framework where applicable, otherwise via the European Commission's Standard Contractual Clauses (SCC).

• Leads: up to 48 months, provided the data subject remains active or engaged
• Inactive leads: deleted or anonymized after 24 months of inactivity
• Marketing: until consent withdrawal
• Analytics: 24 months

Data subjects may exercise their rights by contacting KW Auto at the contact details above. KW Auto is responsible for handling requests relating to the collection and initial processing. For processing carried out by the dealer after lead assignment, the dealer is independently responsible.

• access control and authentication mechanisms
• logging and monitoring of system access
• encryption of data in transit and, where applicable, at rest
• network security controls and firewalls
• regular security testing and vulnerability assessments
• role-based access management
• data minimization and, where applicable, pseudonymization

marketing@kwauto.com