Privacy Policy

Identification of the data controller:

Holder: AUTOCAFLER, S.L.

Registered Office: Carrer de Balcells, 29, Planta baixa, Gracia, 08024 Barcelona.

Autocafler, S.L. (hereinafter referred to as “the Responsible o CAFLER“) is the Controller of the processing of personal data obtained from users through the use of the website www.cafler.com, in accordance with the provisions of 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 (hereinafter “RGPD“); in Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter “LOPDGDD“Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter referred to as “.LSSICE“). The Responsible informs you that it has implemented the necessary technical and organizational security measures to ensure and protect the confidentiality, integrity and availability of the data you provide.

To ensure the proper management in the processing of your personal data, please, any questions you may need, you can contact the Responsible through the following email address: soporte@cafler.com

1. For what purposes and on what legitimate basis do we process personal data?

Purpose of treatment	Additional information	Legitimizing basis
Management and development of the services offered to customers through the website or application of CAFLER.	Provision of the services contracted by the client through the web page of CAFLERThis may include any administrative management necessary for the correct development of the service and/or delivery of the product.	The management, development and maintenance of the contractual relationship maintained with the client.
Manage your registration as a user of the Application	In case you decide to register as a user in our Application, we need to process your data to identify you as a user and give you access to its different functionalities, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us through Customer Service or in the “Unsubscribe” section of the Application. We inform you that the data we collect about your activity, obtained through the different channels of the Platform, including your purchases, will remain linked to your account so that all information can be accessed at once. You have the possibility to use the access or login through a partner with whom you have an account or by registering a new one. In that case, your login credentials, as well as your name and email/phone number (you may need to authorize it), will be imported from your social network or partner account. When using this login option, if the third party sends us certain additional information from your public profile, unless you give us your permission, we will not retain this additional data.	The management, development and maintenance of the contractual relationship with the client.
Fulfillment of legal obligations that may arise from the relationship with the customer.	Fulfillment of any legal obligation that may arise from the contractual relationship with the customer.	Fulfillment of the legal obligations of CAFLER.
Sending of commercial communications.	Sending of the newsletter about new products or services from CAFLER.	Express consent of the client by ticking the box provided for this purpose.
	Sending commercial communications to customers of CAFLER about products or services similar to those contracted.	Legitimate interest of CAFLER in keeping its customers informed about its current offer of products or services.
Management and attention to queries and requests for information sent through the website or Application.	Resolve any questions that may arise to users about our products and / or services, providing the corresponding information.	Legitimate interest* of CAFLER in providing a customer service adequate to the needs of its customers and potential customers (in the context of receiving requests through Social Networks, forms, etc.). Maintenance of the contractual and pre-contractual relationship.
Notify you of changes, important developments to the Privacy Policy or the Terms of Use.	Keep you informed about any relevant changes to the Privacy Policy or the Terms of Use of the website or Application of CAFLER.	Legitimate Interest of CAFLER in providing you with updated information about the conditions of the processing of your personal data and/or the terms of service.
Maintain evidence of the condition of the vehicle at the time of delivery by the customer.	CAFLER may take photographs of the interior and exterior of your vehicle in order to keep proper evidence of its condition (e.g. knocks, damages, objects stored inside, state of cleanliness) at the time of its delivery by you.	Legitimate interest of CAFLER in having the proper evidence of the condition of the vehicle at the moment of its delivery by the client, in order to avoid fraudulent behavior or to be able to prove the correct custody of the vehicle during the provision of its services.
Anonymization of the personal data provided and of the photographs taken of the vehicle.	CAFLER will be able to anonymize the photographs taken in the context of capturing evidence of the vehicle’s condition at the time of delivery, referred to above, in order to produce anonymized statistical analyses on the typology of your customers (for example, to know what percentage of your customers live in large cities, have pets or do winter sports) that will ultimately help you to define your commercial strategy more efficiently and provide value to your business partners. This information, as well as the statistical analysis based on it, which under no circumstances will identify your customers directly or indirectly, will allow us to focus our business strategy in a more efficient way and provide value to our business partners, among other issues.	Legitimate interest of CAFLER to know the average profile of its users and to be able to orientate the web page and the services offered through it accordingly.
To carry out personalized commercial communications prior profiling of its customers.	CAFLER may analyze the photographs taken of the exterior and interior of your vehicle (such as, for example, the model of the vehicle, its condition, the kilometers driven or the equipment of the vehicle such as baby seats, pet accessories or sports equipment) in order to create commercial profiles of its customers in order to send them personalized commercial communications by electronic means, both of its own products or services and those of third parties. For the elaboration of these commercial profiles CAFLER apply analytical models that allow you to have a deeper understanding of your customers’ tastes or preferences, as well as their wealth capacity. To this end, it will process the information indicated above, as well as that which may have been generated internally as a result of the provision of its services.	Express consent of the customer by ticking the box provided for this purpose.
Communication of data to its commercial partners for the purpose of sending personalized commercial communications.	CAFLER may disclose your personal data to its business partners so that they can offer their products and services to you through various channels, including electronic means. These partners may belong to the insurance, banking, automotive, energy or retail sectors, depending on the specific consent you have given us in each case.	Express consent of the customer by ticking the box provided for this purpose.
Use of Cafler Chatbot	By means of this functionality the Controller implements an informative chatbot with personalized behavior to respond to user queries and send them alerts, notifications and reminders on specific conditions about the services offered.	The express consent of the user by ticking the corresponding box when collecting his/her data.
Publication of testimonials.	In the event that the user wants to publish his opinion on the web.	The express consent of the user by ticking the corresponding box when collecting his/her data.
Installation of Cookies.	We use cookies to differentiate our users, learn more about their preferences and offer them a more personalized browsing experience. For more information, please see Section 6 of this Privacy Policy.	The express consent of the User by ticking the corresponding box at the time of data collection.
Satisfaction surveys.	Use your data to contact you, both electronically and non-electronically, to obtain your opinion on the service provided. electronic means, to obtain your opinion on the service provided.	The legitimate interest of the Controller in consulting its users about their degree of satisfaction in relation to the goods and services purchased.
Anonymization of data for statistical purposes.	To carry out a process of anonymization of your personal data in order to prepare reports and statistical studies using aggregated data, which allow us to analyze trends and optimize our services.	The legitimate interest of the Controller in anonymizing the personal data collected for the fulfillment of its own purposes without resorting to the use of personal data.

In relation to the above purposes that are based on the legitimate interest of the Controller, the user may request additional information about how we have assessed our legitimate interest and his or her own rights and interests by contacting us at soporte@cafler.com.

Failure to provide the personal data necessary to execute those purposes covered by the taking of pre-contractual measures or the maintenance of the contractual relationship will mean, for the user, the impossibility to subscribe, register or receive the services provided by the Responsible, since the processing of such data is necessary for the provision of the services offered.

2. To which recipients will your data be communicated?

The Data Controller may communicate your personal data to Public Bodies and Administrations, only when it is necessary for the fulfillment of the applicable legal obligations. It may also communicate your data to subsidiaries for internal administrative purposes.

In addition, and only if you give us your consent to do so, we may disclose your personal data as detailed in section “For what purpose and on what legitimate basis do we process your personal data?“to companies in the insurance, banking, automotive, energy or retail sectors so that they can offer you their products or services, depending on the specific consent you have given us in each case.

In addition, the Controller collaborates with certain third party service providers who process your personal data on its behalf, such as:

• Service providers to deliver, run and support our IT infrastructure
• Self-employed or freelance drivers freelancers who collaborate with the Responsible for providing the services offered.
• Cafler Chatbot Provider.

The Controller follows strict criteria for the selection of service providers in order to comply with its data protection obligations, and formalizes with them the corresponding Processing Assignment Agreement, in accordance with Article 28 of the GDPR. Under no circumstances do these suppliers subcontract services that
share any processing of personal data by third parties without the prior authorization of the Controller.

3. Are there any international data transfers?

The Data Controller does not carry out international transfers of data to third countries in the context of the data processing described in this policy.

4. How long will we keep your personal data?

The period of conservation of your personal data will be determined according to the duration of your relationship with CAFLER and the periods established by law. In this regard, the criteria that CAFLER uses to set the retention periods for your personal data have been determined in accordance with the requirements set out in the applicable legislation, regulations and policy guidelines, as well as the operational requirements of CAFLER s operational requirements related to the correct management of the existing relationship with the different categories of interested parties.

In this sense, your personal data will be kept as long as you do not revoke the consent given or maintain any business or contractual relationship with CAFLER.

Once the same has been completed, your personal data will be deleted as soon as all the necessary actions have been carried out to manage and terminate any remaining obligations between the parties, carrying out all the necessary administrative steps during this period, except in those cases in which the processing of personal data is covered by legitimate interest or consent given, whose data will be processed until the user opposes the processing (unless compelling legitimate interests prevail on the part of the Controller) or withdraws his or her consent.

Notwithstanding the foregoing, your personal data will be kept duly blocked, as long as liabilities may arise from the execution of our contractual or pre-contractual relationship, as well as for the fulfillment of other legal obligations of CAFLER. CAFLER.

In this regard, CAFLER guarantees that it will not process personal data unless it is necessary for the formulation, exercise or defense of claims or when it is required to provide the same to the Public Administration, Judges and Courts during the period of limitation of their legal rights or obligations. Subsequently, your personal data will be deleted.

5. What are your data protection rights?

The user will be able to contact, when he/she deems it necessary, with the Responsible, being able to exercise his/her rights:

• Right of access: You may request access to and copies of your personal data.
• Right of rectificationYou may request that your information be amended if you believe it to be inaccurate and request that additional information be added if you believe it to be incomplete.
• Right to erasure: You may request that your personal data be deleted if it is no longer needed for the purposes identified above; if your data has been unlawfully processed or for compliance with applicable law.
• Right to restrict: You may request that we restrict the processing if you contest the accuracy of your personal data; if it is unlawful and you object to its deletion; if you need it for the establishment, exercise or defense of legal claims or; if you have exercised your right to object.
• Right of opposition: the user can oppose the processing of his personal data so that we stop processing it.

As well as the right to the portability of their data and not to be subject to automated decisions, and to withdraw their consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal, by means of a request addressed to Autocafler, S.L., with registered address at Carrer de Balcells, 29, Planta baixa, Gracia, 08024 Barcelona, or to the following e-mail address soporte@cafler.com

Where there is reasonable doubt as to the identity of the natural person making the request, additional information necessary to confirm the identity of the data subject may be requested.

Finally, in the event that the user wishes to have more information about their rights regarding data protection or needs to file a complaint, they may contact the Spanish Data Protection Agency, located at Calle Jorge Juan, 6, 28001, Madrid, in order to safeguard their rights (www.aepd.es).

6. Use of cookies

The Responsible’s website uses cookies to differentiate it from other users, which helps to provide an optimal browsing experience and to improve the website. Some areas of the website also use cookies to learn more about you and provide you with a more personalized experience. We process this personal data to:

• To ensure that content on our site is presented in the most effective manner for you and your device.
• Administer the website and perform internal operations such as troubleshooting, data analysis, testing, research, statistics and surveys.
• Allow the user to participate in interactive features of the services, if desired.
• Keep our website safe and secure.

You can find all the details in our Cookies Policy:

cafler.com/cookie-policy/

7. Modification of privacy and data protection policy

Autocafler, S.L., reserves the right to modify this privacy and data protection policy to adapt it to current regulations at all times and to the instructions or recommendations issued by the control authorities, so we recommend reading it before each access and navigation through the website.

8. Keep your personal data up to date

We strive to maintain the accuracy and integrity of the personal data we hold. It is essential that you inform us of any updates to your contact or other personal information to ensure that we have the most up-to-date information about you. Please contact us for any updates via email: support@cafler.com

Last updated July 16, 2025.