Third Party Index

Snapshot 62552

Document
Data processing addendum
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https://www.nextlane.com/wp-content/uploads/2024/10/AppendixNextlaneDataProcessingAgreement.pdf
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ce7e32346d9ef43d9885fc6a7da8660104ae695e9a5a3fbc0f4d97e0202222e0

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                            DATA PROCESSING AGREEMENT
This Data Processing Agreement (DPA) is an exhibit to the Terms and Conditions and forms an integral
part of the Agreement entered into by Nextlane and the Customer.
Capitalized terms used but not defined in this Data Processing Agreement shall have the meanings
provided in Nextlane’s Terms and Conditions.

1.    Definitions
      For the purpose of this DPA, the capitalized terms shall have the meaning set forth below:

1.1   "Data Protection Laws” shall have the meaning set forth in article 1.16 of Nextlane Terms and
      Conditions.

1.2   "Data Breach” means any event leading to the accidental or unlawful destruction, loss,
      alteration, unauthorized disclosure of or access to the Customer’s Personal Data by any third
      party.

1.3   “Data Controller” or “Controller” means the legal person which determines the purposes and
      means of the Processing of Personal Data.

1.4   “Data Processor” or “Processor” means the legal person which processes Personal Data on
      behalf of the Data Controller and in accordance with its instructions.

1.5   "Data Subject" means an identified or identifiable natural person whose Personal Data is being
      processed under this DPA.

1.6   “Personal Data” means any information relating to a Data Subject.

1.7   "Processing” and “Process” means any operation or set of operations which is performed on
      Personal Data or on sets of Personal Data, whether by automated means, such as collection,
      recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use,
      disclosure by transmission, dissemination or otherwise making available, alignment or
      combination, restriction, erasure or destruction. The Processing is described in Annex
      “Processing description” attached to this DPA.

2.    Processing
      The Parties acknowledge that for the performance of the Agreement, the Customer acts as Data
      Controller and that Nextlane acts as a Data Processor.

3.    Obligations of Nextlane as Data Processor

3.1   General obligations
      Nextlane undertakes to:
         (i) process the Personal Data in accordance with Customer’s documented instructions and
               for the sole purposes set forth in Annex “Processing description”.
         (ii) notify immediately Customer if Nextlane considers that an instruction constitutes a
               violation of the Data Protection Laws.
         (iii) not to use the Personal Data for purposes other than those necessary for the performance
               of this DPA.
          (iv) ensure that the persons authorized to Process Personal Data under this DPA are
               committed to confidentiality or are subject to an appropriate legal obligation of
               confidentiality and receive the necessary training regarding personal data protection.
          (v) take all appropriate measures, including physical security measures, to ensure the
               protection of the Personal Data throughout the duration of the Agreement.
          (vi) to comply with the retention periods provided in Annex “Processing description”.

3.2   Security and confidentiality
      Nextlane undertakes to implement the appropriate technical and organizational measures in order
      to ensure a level of security appropriate to the risk, including, among other things:
          (i) means to ensure the ongoing confidentiality, integrity, availability and resilience of
                processing systems and services.
          (ii) means to restore the availability of, and access to, Personal Data within an appropriate
                timeframe in the event of a physical or technical incident.
          (iii) a procedure for regularly testing, analyzing and evaluating the effectiveness of technical
                and organizational measures for ensuring the security of processing.

3.3   Assistance to the Customer
      Nextlane undertakes to:
         (i) assist the Customer to fulfil its obligation to respond to Data Subjects’ requests. When
               Data Subjects send requests to Nextlane to exercise their rights, Nextlane shall forward
               these requests to the Customer.
         (ii) assist the Customer to perform data privacy impact assessments of the Processing carried
               out under the Agreement (if such assessment is required by Data Protection Laws).
         (iii) make available to the Customer the necessary documentation to demonstrate compliance
               with its obligations under the Data Protection Laws and to contribute to audits under the
               conditions set forth in article 3.8 “Audit”.

3.4   Data Breach
      Nextlane shall notify the Customer of any Data Breach as quickly as possible after being made
      aware of it. This notification shall include all useful documentation in order to enable the
      Customer, if necessary, to notify the competent authority and / or the Data Subjects of this
      violation and in particular:
          (i) a description of the nature of the Data Breach including, if possible, the categories and
                approximate number of Data Subjects and Personal Data records concerned.
           (ii) a description of the likely consequences of the Data Breach.
          (iii) a description of the measures taken or proposed to be taken by the Customer to address
                the Data Breach, including, where appropriate, measures to mitigate any adverse
                consequences.

3.5   Subcontracting
      The Customer authorizes Nextlane to engage subcontractors ("the Subsequent Data Processor")
      for carrying out specific processing activities on behalf of the Customer.
      The List of authorized Subsequent Data Processor is provided in Annex “Processing description”.
      Where applicable, Nextlane is required to inform the Customer in advance of any planned
      modifications concerning the addition or replacement of other Subsequent Data Processor, giving
      the Customer the possibility of objecting to such modifications for a legitimate reason.
      In the absence of written objection from the Customer within 10 (ten) Business Days following
      the notification sent by Nextlane, the Customer shall be deemed to have accepted the addition or
      replacement of the Subsequent Data Processor.
      In the event of a legitimate objection by the Customer regarding the addition or replacement of a
      Subsequent Data Processor, the Parties shall meet as soon as possible to find an alternative
      solution that is commercially reasonable for Nextlane. If no amicable solution can be found within
      a reasonable time, the Agreement may be terminated by either Party.
      The Subsequent Data Processor shall be committed to comply with the Customer’s instructions.
      Nextlane shall ensure that the Subsequent Data Processor offers the same sufficient guarantees
      regarding the implementation of appropriate technical and organizational measures. Nextlane
      remains liable to the Customer for the performance by the Subsequent Data Processor of its
      obligations.

3.6   Territory and hosting
      Nextlane does not transfer any Personal Data from Switzerland and/or from the EEA to a third
      country that does not provide an adequate level of protection (as defined by article 16.1 of the
      nFADP and articles 44 et seq of GDPR) without taking appropriate safeguards required by
      Applicable Laws.

3.7   Disclosure of Personal Data

      Nextlane will not disclose or provide access to any Personal Data to law enforcement unless
      required by Applicable Law. If law enforcement contacts Nextlane with a demand for Personal
      Data, Nextlane will redirect the law enforcement agency to request these Personal Data directly
      from the Customer. If compelled to disclose or provide access to any Personal Data to law
      enforcement, Nextlane will promptly notify the Customer and provide a copy of the demand
      unless legally prohibited from doing so.

3.8   Audit
      To the extent Customer’s audit requirements cannot reasonably be satisfied through audit reports
      and documentation Nextlane makes generally available to Customer, Nextlane will promptly
      respond to Customer’s additional audit instructions.
      Before the commencement of an audit, Nextlane and the Customer will mutually agree upon the
      scope, timing, and duration of the audit. To the extent needed to perform the audit, Nextlane will
      make the systems and supporting documentation relevant to the processing of Customer’s
      Personal Data available.
      Such an audit will be conducted by the Customer or by an independent, accredited third-party
      audit firm, during regular business hours, with advance notice of at least 15 (fifteen) Business
      Days and subject to confidentiality obligation. Neither the Customer nor the auditor shall have
      access to any data from Nextlane’s other customers or to Nextlane systems or facilities not
      involved in the Services.
      Customer shall bear all costs and fees related to the audit, including reasonable costs for the time
      Nextlane expends for such audit. The audit report generated as a result of the audit shall be shared
      with Nextlane. If the audit report includes any finding of a material non-compliance, Nextlane
      shall promptly cure such non-compliance.

3.9   Termination
      Upon termination of the Agreement, Nextlane undertakes to destroy all manual or computerized
      files storing the Personal Data and any existing copies thereof, unless Applicable Law requires
      their retention.
4.   Obligations of the Customer as Data Controller
     The Customer acting as Data Controller, shall comply with Data Protection Laws and in particular
     undertakes to:
        (i) ensure that Data Subjects’ rights are respected. In particular, the Customer is solely
              responsible for providing the Data Subjects with accurate and complete information
              regarding the Processing of their Personal Data.
        (ii) document in writing any instructions given to Nextlane regarding the Processing of
              Personal Data carried out by Nextlane or its Subsequent Data Processor under the
              Agreement.
        (iii) comply with the purposes of the Processing.
        (iv) refrain from providing Nextlane with instructions that may contravene the Data
              Protection Laws.
        (v) carry out all procedures, assessments and authorizations that may be required by Data
              Protection Laws to Process the Personal Data.

     In this context, the Customer shall hold harmless and indemnify Nextlane against the financial
     and legal consequences of any action, claims, or dispute that may be brought against Nextlane
     based on the failure of the Customer to comply with its legal obligations as Data Controller.

5.   Contact persons in charge of data privacy
     -   For Nextlane: dpo@nextlane.com
     -   For the Customer: [name and email address]
                       ANNEX to the Data Processing Agreement
                               Description of ERIS MOTORS

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

• Nature of the Processing:
   Collection of Data Controller’s customers and/or prospects and/or employee’s personal data by
   the Data Controller that are integrated in the DMS of the Data Processor, with the objective of
   enhancing the services that the Data Controller can provide to its own customers.
   The processing can relate to the sales of vehicles, after-sales activities, spare parts management,
   and accounting management depending on the type of subscription selected by the Data
   Controller. The Processing also covers the connection with relevant car manufacturers to provide
   multiple services and manage customers’ interaction.

• Purposes of Processing are the following:
   depending on the services subscribed by the Data Controller:
      -   Support for the Data Controller in managing its relationship with its Prospects:
           o    Organisation of vehicle test
      -   Support for the Data Controller in managing its relationship with its Customers:
           o Management of vehicle purchase
           o Management of vehicle trade-in
           o Organization of vehicle maintenance and test
           o Management of parts orders and warranty with the OEM
           o Management of courtesy vehicle
           o Management of registration process of the vehicle
      -   Support for the Data Controller in managing its internal organizational
           o Workshop organization
           o Courtesy vehicle management.

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Nextlane – DPA – Eris Motors DMS – September 2024
Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                 Management of                                Management of Data
                                                         Management of
Data Subject categories            Prospects                                  Controller’s internal
                                                          Customers
                                                                                 organization
Data Controller’s Prospects                X                                             X
Data Controller’s
                                           X                    X                        X
Employees
Data Controller’s
                                                                X                        X
Customers
Data Controller’s Suppliers                                     X                        X
Car driver                                 X                    X                        X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

             Category of Personal Data                                  Details

                                                    Gender, name, surname, address, phone number,
   Civil Status, ID, identification data
                                                    e-mail address
   Economic and financial information               Bank account number, workplace and title

For the purpose of management of Data Controller’s Customers

             Category of Personal Data                                   Details

                                                    Gender, name, surname, address, phone number,
  Civil Status, ID, identification data
                                                    e-mail address
  Economic and financial information                Bank account number
  Information related to the vehicle                Vehicle Identification Number, license plate
  Other type of Personal Data                       Language

Nextlane – DPA – Eris Motors DMS – September 2024
For the purpose of management of Data Controller’s internal organization

             Category of Personal Data                                    Details

    Civil Status, ID, identification data               Name, surname

•    Contact in charge of Data Protection matter

                   Data Controller                                     Data Processor

    Name: [•]                                           Email address: dpo@nextlane.com
    Email address: [•]                                  Postal address: 190 avenue Thiers, 69006
                                                        Lyon, France
    Postal address: [•]

Location(s) of Processing operations

     - The Data Processor operates in the European Union and Switzerland.
     - The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processings
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

          Name              Location                         Processing activity

 TMS                       France            MiSIV is a Solution dealing with the registration of
                                             the vehicle (TMS is a Data Processor’s Group
                                             company)

 Esker                     France           Digital invoice solution

Nextlane – DPA – Eris Motors DMS – September 2024
                        ANNEX to the Data Processing Agreement
                                  Description of I’CAR DMS

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•     Nature of the Processing:
      Collection of Data Controller’s customers and/or prospects and/or employee’s personal data
      by the Data Controller that are integrated in the DMS of the Data Processor, with the objective
      of enhancing the services that the Data Controller can provide to its own customers.
      The processing can relate to the sales of vehicles, after-sales activities, spare parts
      management, and accounting management depending on the type of subscription selected by
      the Data Controller. The Processing also covers the connection with relevant car
      manufacturers to provide multiple services and manage customers’ interaction.

•     Purposes of Processing are the following:
      depending on the services subscribed by the Data Controller:
      -      Support for the Data Controller in managing its relationship with its Prospects:
             o    Management of leads
             o    Management of vehicle offers
             o    Organisation of vehicle test
             o    Management of marketing campaigns.
      -      Support for the Data Controller in managing its relationship with its Customers:
             o    Management of vehicle purchase
             o    Management of vehicle trade-in
             o    Organization of vehicle maintenance and test
             o    Management of parts orders and warranty with the OEM
             o    Management of courtesy vehicle
             o    Management of registration process of the vehicle
             o    Storage of administrative documents
             o    Management of marketing campaigns
             o    Publishing of Used Car pictures and information on Web sites
             o    Evaluation of vehicle value
      -      Support for the Data Controller in managing its internal organizational
             o    Workshop organization
             o    Courtesy vehicle management
             o    Time recording of its Employees
             o    Sales related commission and/or incentives of its Employees.

Nextlane – DPA – I’CAR DMS – September 2024
Retention Period

The Data Controller shall provide to the Data Processor the retention policy of personal data,
which is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                                                           Management of Data
                                 Management of       Management of
Data Subject categories                                                    Controller’s internal
                                   Prospects          Customers
                                                                              organization
Data Controller’s Prospects                X                                         X
Data Controller’s
                                           X                   X                     X
Employees
Data Controller’s
                                                               X                     X
Customers
Data Controller’s Suppliers                                    X                     X
Car driver                                 X                   X                     X

Categories of Personal Data

Personal Data processed related to the following categories:

For the purpose of management of Data Controller’s Prospects

             Category of Personal Data                              Details

                                               Gender, name, surname, address, phone number,
   Civil Status, ID, identification data       e-mail address, ID number, driving license
                                               number, date of birth, place of birth
   Economic and financial information          Bank account number, workplace and title
                                               Vehicle Identification Number, license plate,
   Information related to the vehicle
                                               insurance number
   Personal information                        Interest, hobbies,
   Other type of Personal Data                 Language

Nextlane – DPA – I’CAR DMS – September 2024
For the purpose of management of Data Controller’s Customers

            Category of Personal Data                                Details

                                                Gender, name, surname, address, phone number,
    Civil Status, ID, identification data       e-mail address, ID number, driving license
                                                number, date of birth, place of birth
    Economic and financial information          Bank account number
                                                Vehicle Identification Number, license plate,
    Information related to the vehicle
                                                insurance number
    Other type of Personal Data                 Language, consent form

For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                Details

                                                 Name, Surname, Address, ID number, Phone
    Civil Status, ID, identification data
                                                 number, e-mail address
                                                 Internal employee ID, working date and absence
    Information related to employment
                                                 time, date of sales, commissions and incentives

Contact in charge of Data Protection matter

                  Data Controller                                Data Processor

    Name: [•]                                    Email address: dpo@nextlane.com
    Email address: [•]                           Postal address: 190 avenue Thiers, 69006 Lyon,
    Postal address: [•]                          France

Location(s) of Processing operations

-        The Data Processor operates in the European Union and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

Nextlane – DPA – I’CAR DMS – September 2024
List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available in specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

          Name            Location                      Processing activity

                                        MiSIV is a Solution dealing with the registration of
 TMS                     France         the vehicle (TMS is a company of the Data Processor
                                        Group)

                                        LPN is a Solution dealing with the management of
 TMS                     France
                                        official document related to sales of vehicle

 Esker                   France         Digital invoice solution interfaced

 SAGE                    France         Solution for accounting purpose

 AMS                     Germany        Integration Partner

 3DSoft                  France         Mecaplanning – organisation of the workshop

                                        Management of vehicle (creation of file on new
 Autovista               France
                                        vehicle, vehicle specifications)

Nextlane – DPA – I’CAR DMS – September 2024
                      ANNEX to the Data Processing Agreement
                              Description of KOBRA II DMS

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing
•    Nature of the Processing:
     Collection of Data Controller’s customers personal data by the Data Controller that are
     integrated in the DMS of the Data Processor, with the objective of enhancing the services that
     the Data Controller can provide to its own customers, in Sweden automotive market.
     The Processing can relate to the sales of vehicles, after-sales activities, spare parts and repair
     management, depending on the type of subscription selected by the Data Controller. The
     Processing also covers the connection with relevant car manufacturers to provide multiple
     services and manage customers’ interaction.

•    Purposes of Processing are the following:
     Depending on the services subscribed by the Data Controller:
     -    Support for the Data Controller in managing its relationship with its Customers:
          o  Management of vehicle purchase
          o  Management of vehicle trade-in
          o  Organization of vehicle maintenance and test
          o  Management of parts orders and warranty with the OEM
          o  Management of courtesy vehicle
          o  Management of registration process of the vehicle
          o  Storage of administrative documents.
     -    Support for the Data Controller in managing its internal organization:
          o  Workshop organization
          o  Courtesy vehicle management.

Retention period

The Data Controller shall provide to the Data Processor the retention policy of Personal Data,
which is aligned with the principles provided for by Applicable Law.

Nextlane – DPA – KOBRA II DMS – September 2024
Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                                               Management of Data
                                         Management of
           Data Subject categories                             Controller’s internal
                                          Customers
                                                                  organization
           Data Controller’s
                                                 X                        X
           Employees
           Data Controller’s
                                                 X                        X
           Customers
           Data Controller’s Suppliers           X                        X
           Car driver                            X                        X

Categories of Personal Data

Personal Data processed relates to the following categories:

For the purpose of management of Data Controller’s Customers

         Category of Personal Data                                    Details

                                               Gender, name, surname, address, phone number,
 Civil Status, ID, identification data related e-mail address, ID number, driving license
 to Customers/drivers
                                               number, date of birth.
                                                 Vehicle Identification Number, license plate,
 Information related to the vehicle
                                                 insurance number
 Other type of Personal Data                     Language, consent form

For the purpose of management of Data Controller’s internal organization

         Category of Personal Data                                    Details

                                                 Gender, name, surname, address, phone number,
 Civil Status, ID, identification data
                                                 e-mail address
                                                 Vehicle Identification Number, license plate,
 Information related to the vehicle
                                                 insurance number

Nextlane – DPA – KOBRA II DMS – September 2024
Contact in charge of Data Protection matter

                   Data Controller                              Data Processor

    Name: [•]                                    Email address: dpo@nextlane.com
    Email address: [•]                           Postal address: 190 avenue Thiers, 69006
                                                 Lyon, France
    Postal address: [•]

Location(s) of Processing operations

-       The Data Processor operates in the European Union and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Transfer occurs through the Subsequent Data Processor mentioned below to Philippines for
digitization of documents by CGI Philippines Inc. Such transfer from C.G.I Sverige AV to C.G.I.
Philippines Inc. is covered by BCR.

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processings
mentioned below might be available in specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

              Name           Location                     Processing activity

                                          Digitization of documents with sub-processors in EU
      C.G.I. Sverige AB      Sweden
                                          and Philippines

                                          Agda Payroll system : time stamp function and
      Visma AB               Sweden
                                          payroll costs

      Gordion AB             Sweden       self-service kiosk for repair

      Quadratura Nordic
                             Sweden       self-service kiosk for repair
      AB

      Autoinnovation ApS
                             Sweden       self-service kiosk for repair
      (tjekvik)

Nextlane – DPA – KOBRA II DMS – September 2024
           Name            Location                       Processing activity

                                          Digital solutions for the automotive industry, focusing
   Bilvision AB            Sweden
                                          on vehicle data and systems.

                                          Offers software and services related to automotive
   Clifford Thames         UK
                                          data and supply chain management.

   Atoy Automotive                        Distributes automotive spare parts and provides
                           Sweden
   Sweden AB                              related services across Scandinavia.

   Resurs Bank                            A Nordic bank offering consumer finance, payment
                           Sweden
   Aktiebolag                             solutions, and savings products.

   EXDE Systems AB                        Provides software and IT solutions, specializing in
                           Sweden
   (BUMS)                                 management systems for businesses.

                                          Develops software for the insurance and automotive
   CAB Group AB            Sweden         industries, particularly around repair and claims
                                          management.

                                          Offers digital solutions and consultancy for business
   Wisentic AB             Sweden
                                          process optimization.

                                          Provides enterprise-level software, data, and solutions
   Snap-on Business                       that help manage parts, service, and sales operations
                           UK
   Solutions Inc                          for manufacturers and dealerships in the automotive,
                                          construction, and powersports industries

                                          Focuses on customer interaction solutions, including
   NG Dialogue AB          Sweden
                                          telemarketing and customer service outsourcing.

   Autoexperten I                         A Swedish chain of automotive repair shops and spare
                           Sweden
   Sverige AB                             parts distributors.

                                          A leading European company in the automotive
   Meko AB                 Sweden         aftermarket sector, providing services and products
                                          for vehicle maintenance.

                                          Global provider of software solutions that help
                                          automotive dealerships and manufacturers manage
   Infomedia Ltd           UK             parts, service, and customer relations, specializing in
                                          electronic parts catalogues, service quoting, and data
                                          analytics

                                          Develops software solutions, particularly focused on
   Sweet Systems AB        Sweden
                                          vehicle fleet management and logistics.

   Transdev Sverige                       An international company offering public transport
                           Sweden
   AB                                     services, including bus, tram, and train operations.

Nextlane – DPA – KOBRA II DMS – September 2024
             Name          Location                       Processing activity

                                          One of Norway's largest financial institutions,
   DNB Bank                Norway
                                          offering banking, investment, and insurance services.

                                          Automotive software company providing digital
   Keyloop                 UK
                                          solutions for car dealerships and manufacturers.

                                          Specializes in customer loyalty solutions, including
   Loyalty Logistix        UK             software for customer engagement and retention
                                          programs.

   Biluthyrarna Sverige                   A Swedish association representing car rental
                           Sweden
   AB                                     companies and related services.

                                          A leading global manufacturer of lubricants and fluids
   Castrol                 UK
                                          for automotive, industrial, and marine applications.

                                          An online platform for automotive spare parts,
   Bildelsbasen AB         Sweden         serving consumers and businesses in the Nordic
                                          region.

   InMoment (Vital                        Customer experience management and feedback
                           Canada
   Insights)                              solutions, particularly in the automotive sector.

                                          A division of ETL Solutions specializing in data
   ETL Solutions
                           UK             integration for automotive companies, particularly
   (Mobis)
                                          Hyundai Mobis.

   Mercur Solutions                       A Swedish company providing performance
                           Sweden
   AB                                     management and business intelligence software.

                                          A Swedish branch of the global advisory, broking, and
                                          solutions company, providing services in risk
   Willis Towers
                           Sweden         management, insurance brokerage, human capital
   Watson Sweden AB
                                          consulting, and benefits management to businesses
                                          across various industries.

   Care of CRM AB                         Provides customer relationship management (CRM)
                           Sweden
   (Cirrus)                               solutions and consulting services.

                                          A Swedish company specializing in the sale of used
   Recopart AB             Sweden
                                          automotive spare parts.

                                          A Swedish payment service company providing
   Bankgirocentralen
                           Sweden         clearing and settlement of transactions between
   BGC Aktiebolag
                                          banks.

                                          Offers accounts payable automation solutions for
   Rillion AB              Sweden
                                          businesses, helping to streamline invoice processing.

Nextlane – DPA – KOBRA II DMS – September 2024
                       ANNEX to the Data Processing Agreement
                                     Description of MaxSat

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•     Nature of the Processing:
      The Processing consists of the use of personal data from the Data Controller’s customers to
      launch customer satisfaction surveys and to publish their comments and rating on a specific
      webpage of the Data Processor.

•     Purposes of Processing are the following:
      -   Operation relating to the collection of satisfaction following invoicing (score, comment,
          dissatisfaction criteria, if necessary, type of intervention carried out).
      -   Operations relating to the restitution, to the Data Controller, of the opinion of its
          customers in tools with specific access by the Data Controller and elaboration of
          anonymous statistical reports on responses.
      -   Identification of a purchase project.
      -   Option to share said review on third review platforms: collection of consent from Data
          Controller’s Customers.

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are those of the Data Controller’s invoiced
Customers.

Nextlane – DPA – MaxSat – September 2024
Categories of Personal Data

-      For the purpose of collecting satisfaction following invoicing

             Category of Personal Data                                  Details

                                                  Name, surname, address, phone number, e-mail
    Civil Status, ID, identification data
                                                  address
    Economic and financial information            Invoice number
                                                  Date of the intervention or delivery of the
    Information related to the vehicle
                                                  vehicle, brand and model of the vehicle
    Connection data                               IP address, logs

-    For the purpose of restitution of the opinion of the Customer

             Category of Personal Data                                  Details

    Civil Status, identification data             Name, surname, or alias
                                                  brand and model of the vehicle, new or used
    Information related to the vehicle
                                                  vehicle category
    Others                                        Space available for free comments
    Connection data                               IP address, logs

-    For the purpose of identification of a purchase project

             Category of Personal Data                                  Details

    Civil Status, identification data             Name, surname, or alias
                                                  New or used vehicle brand and model of the
    Information related to the vehicle
                                                  vehicle,
    Connection data                               IP address, logs

       -      For the purpose of sharing said review on third platforms:

             Category of Personal Data                                  Details

    Civil Status, identification data             Name, surname, e-mail address
    various                                       Rating score

Nextlane – DPA – MaxSat – September 2024
Location(s) of Processing operations

-       The Data Processor operates in the European Union, and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

          Name            Location                          Processing activity

    AWS                   European         Storage – cloud solution
                          Union

    Mailgun               European         Launch of e-mail campaigns
                          Union

    SMS Factors           FRANCE           Launch of text campaigns

Nextlane – DPA – MaxSat – September 2024
                         ANNEX to the Data Processing Agreement
                                       Description of BI360
Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•      Nature of the Processing:
       BI360 is integrated solutions with the Data Processor’s DMS (Dealer Management Systems)
       and CRM (Customer Relationship Management). It enables the Data Controller to create its
       own performance indicators related to the sale and servicing of used and new cars.

•      Purposes of Processing are the following:
       -   Create reports and KPI
       -   Improvement of the Data Controller’s performance by using the data issued from the DMS
           and/or CRM

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

              Data Subject categories
              Data Controller’s Prospects                            X
              Data Controller’s Customers                            X

Categories of Personal Data

Personal Data processed relate to the following categories:

           Category of Personal Data                                Details

                                               Name, surname, address, phone number,
    Civil Status, ID, identification data
                                               Customer ID
                                               Vehicle Identification Number, license plate
    Data linked to a vehicle
                                               number

Nextlane – DPA – BI360 – September 2024
Contact in charge of Data Protection matter

                   Data Controller                               Data Processor

    Name: [•]                                    Email address: dpo@nextlane.com
    Email address: [•]                           Postal address: 190 avenue Thiers, 69006 Lyon,
                                                 France
    Postal address: [•]

Location(s) of Processing operations

-       The Data Processor operates in the European Union, and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

None

List of Subsequent Data Processors

None

Nextlane – DPA – BI360 – September 2024
                     ANNEX to the Data Processing Agreement
                                  Description of DataCar

Controller

The Data Controller is the Customer.

Nature and purpose of Processing

•    Nature of the Processing:
     Collection of Data Controller’s customers and/or prospects and/or employee’s Personal
     Data by the Data Controller that are integrated in the DMS of the Data Processor, with
     the objective of enhancing the services and sales that the Data Controller can provide to
     its own Customers.
     The Processing can relate to the sales of vehicles, after-sales activities, spare parts
     management, and accounting management depending on the type of subscription selected
     by the Data Controller.

•    Purposes of Processing are the following:
     Depending on the services subscribed by the Data Controller:
     -       Support for the Data Controller in managing its relationship with its customers:
             o    Management of vehicle purchase
             o    Management of vehicle trade-in
             o    Organization of vehicle maintenance and test
             o    Management of courtesy vehicle
             o    Management of registration process of the vehicle
             o    Storage of administrative documents
     -       Support for the Data Controller in managing its internal organizational
             o    Workshop organization
             o    Courtesy vehicle management

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data,
which is aligned with the principles provided by Applicable Law.

Nextlane – DPA – DATACAR DMS – September 2024
  Categories of Data Subjects

  The Personal Data processed by the Data Processor are related to the following categories of
  Data Subjects:

                                                                        Management of Data
                                     Management of Customer
                                                                       Controller’s Employees

Data Controller’s Employees                     X                                 X

Data Controller’s Customers                     X

Data Controller’s Suppliers                     X

Car driver                                      X

  Categories of Personal Data

  Personal Data processed relate to the following categories:

  For the purpose of management of Data Controller’s Customers

         Category of Personal Data                              Details

                                        Gender, name, surname, address, phone number,
       Civil Status, ID, identification e-mail address, ID number, driving license
       data
                                        number, date of birth, place of birth

       Economic       and       financial Bank account number
       information

       Information    related   to    the Vehicle Identification Number, license plate,
       vehicle                            insurance number

       Other type of Personal Data         language

  For the purpose of management of Data Controller’s internal organization

         Category of Personal Data                              Details

       Civil Status, ID, identification Name, Surname, Address, ID number, date of
       data                             birth, place of birth of Employees

  Nextlane – DPA – DATACAR DMS – September 2024
Contact in charge of Data Protection matter

                Data Controller                               Data Processor

    Name: [•]                               Email address: dpo@nextlane.com
    Email address: [•]                      Postal address: 190 avenue Thiers, 69006
                                            Lyon, France
    Postal address: [•]

Location(s) of Processing operations

-         The Data Processor operates in the European Union and Switzerland.
-         The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an
adequacy decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the
add-ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

            Name            Location                      Processing activity

    TMS                    France       MiSIV is a Solution dealing with the registration of the
                                        vehicle (TMS is a subsid

    CGI                    Italy        Integration partner

    Esker                  France       Digital invoice solution interfaced with DataCar if
                                        subscribed by the Data Controller

    Motorsoft              Portugal     Integration partner

    Wizrom                 Romania      Integration partner

Nextlane – DPA – DATACAR DMS – September 2024
                         ANNEX to the Data Processing Agreement
                                  Description of Digital Invoice
Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•      Nature of the Processing:
       Digital Invoice is integrated solutions with the Data Processor’s DMS (Dealer Management
       Systems). It enables the Data Controller to digitize, distribute and archive all its customers’
       invoices.

•      Purposes of Processing are the following:
       -   Invoicing of transactions related to the sales, trade-in, maintenance and repair of vehicle
       -   Archiving of such invoices
       -   Automatic distribution of invoice

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

              Data Subject categories
              Data Controller’s Employees                               X
              Data Controller’s Customers                               X
              Data Controller’s Suppliers (auditors,                    X
              agents…)

Categories of Personal Data

Personal Data processed relate to the following categories:

           Category of Personal Data                                   Details

                                                    Name, surname, address, phone/fax number, e-
    Civil Status, ID, identification data
                                                    mail address, job title

Nextlane – DPA – Digital Invoice – September 2024
Contact in charge of Data Protection matter

                   Data Controller                                   Data Processor

    Name: [•]                                        Email address: dpo@nextlane.com
    Email address: [•]                               Postal address: 190 avenue Thiers, 69006 Lyon,
                                                     France
    Postal address: [•]

Location(s) of Processing operations

-       The Data Processor operates in the European Union, and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland, or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Dara Processors used by the Data Processor depends on the add-ons or DMS
subscribed by the Data Controller.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

           Name             Location                        Processing activity

    ESKER                  France          Supplier of the digital invoice solution which the Data
                                           Processor is reselling to the Data Controller

Nextlane – DPA – Digital Invoice – September 2024
                         ANNEX to the Data Processing Agreement
                                Description of Digital Signature
Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•      Nature of the Processing:
       Digital Signature is integrated solutions with the Data Processor’s DMS and CRM (Dealer
       Management Systems). It enables the Data Controller to digitize, distribute and archive all
       signatures linked to contractual documents related to the sale and servicing of a vehicle.

•      Purposes of Processing are the following:
       -   Signature of transactions related to the sales, trade-in, maintenance and repair of vehicle
       -   Archiving of such signatures
       -   Electronic distribution of signed documents

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided for by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

              Data Subject categories
              Data Controller’s Employees                                X
              Data Controller’s Customers                                X
              Data Controller’s Suppliers (auditors,                     X
              agents…)

Categories of Personal Data

Personal Data processed relate to the following categories:

           Category of Personal Data                                     Details

                                                      Name, surname, address, phone number, e-mail
    Civil Status, ID, identification data
                                                      address, job title

Nextlane – DPA – Digital Signature – September 2024
Contact in charge of Data Protection matter

                   Data Controller                                   Data Processor

    Name: [•]                                         Email address: dpo@nextlane.com
    Email address: [•]                                Postal address: 190 avenue Thiers, 69006 Lyon,
                                                      France
    Postal address: [•]

Location(s) of Processing operations

-       The Data Processor operates in the European Union and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depend on the add-ons or DMS/CRM
subscribed by the Data Controller.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

The Data Processor uses the following Subsequent Data Processors:

           Name             Location                        Processing activity

    Uanataca               Spain           Electronic signature provider

    Labsmobile             Spain           SMS provider

Nextlane – DPA – Digital Signature – September 2024
                       ANNEX to the Data Processing Agreement
                                Description of DRIVE DMS

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•   Nature of the Processing:
    Collection of Data Controller’s customers and/or prospects and/or employee’s personal data by
    the Data Controller that are integrated in the DMS of the Data Processor, with the objective of
    enhancing the services that the Data Controller can provide to its own customers.
    The Processing can relate to the sales of vehicles, after-sales activities, spare parts management,
    and accounting management depending on the type of subscription selected by the Data
    Controller. The Processing also covers the connection with relevant car manufacturers to
    provide multiple services and manage customers’ interaction.

•   Purposes of Processing are the following:
    depending on the services subscribed by the Data Controller:
    -     Support for the Data Controller in managing its relationship with its Prospects:
           o Management of leads
           o Management of vehicle offers
           o Management of marketing campaigns.
    -     Support for the Data Controller in managing its relationship with its Customers:
           o   Management of vehicle purchase
           o   Management of vehicle trade-in
           o   Organization of vehicle maintenance and test
           o   Management of parts orders and warranty with the OEM
           o   Management of courtesy vehicle
           o   Storage of administrative documents
           o   Management of marketing campaigns
           o   Publishing of Used Car pictures and information on Web sites
           o   Evaluation of vehicle value
    -     Support for the Data Controller in managing its internal organizational
           o   Workshop organization
           o   Courtesy vehicle management
           o   Management of leads
           o   Management of marketing campaigns
           o   Evaluation of a vehicle value
           o   Management of Employees (timing)

Nextlane – DPA – Drive DMS– September 2024
Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                 Management of                            Management of Data
                                                    Management of
  Data Subject categories          Prospects                              Controller’s internal
                                                     Customers
                                                                             organization
Data Controller’s Prospects               X                                          X
Data Controller’s Employees               X                 X                        X
Data Controller’s Customers                                 X                        X
Data Controller’s Suppliers                                 X                        X
Car driver                                X                 X                        X

Categories of Personal Data

Personal Data processed relates to the following categories:

For the purpose of management of Data Controller’s Prospects

         Category of Personal Data                                  Details

                                               Gender, name, surname, address, phone number,
  Civil Status, ID, identification data        e-mail address, driving license number, date of
                                               birth
  Economic and financial information           Bank account number, workplace and title
                                               Vehicle Identification Number, license plate,
  Information related to the vehicle
                                               insurance number
  Personal information                         Interest, hobbies,
  Other type of Personal Data                  Language, workplace, title, consent

Nextlane – DPA – Drive DMS– September 2024
For the purpose of management of Data Controller’s Customers

             Category of Personal Data                               Details

                                                Gender, name, surname, address, phone number,
    Civil Status, ID, identification data
                                                e-mail address, date of birth, place of birth
    Economic and financial information          Bank account number
                                                Vehicle Identification Number, license plate,
    Information related to the vehicle
                                                insurance number
    Other type of Personal Data                 Language, consent form, workplace, title

For the purpose of management of Data Controller’s internal organization

             Category of Personal Data                               Details

                                                 Gender, name, surname, address, phone number,
    Civil Status, ID, identification data
                                                 e-mail address, date of birth, place of birth
    Financial information                        Bank account number
                                                 Date of hire, internal employee ID, working date
    Information related to employment
                                                 and absence time

•     Contact in charge of Data Protection matter

                   Data Controller                             Data Processor

    Name: [•]                                     Email address: dpo@nextlane.com
    Email address: [•]                            Postal address: 190 avenue Thiers, 69006
                                                  Lyon, France
    Postal address: [•]

Location(s) of Processing operations

         -   The Data Processor operates in the European Union and Switzerland.
         -   The Data Controller operates in __________________

Data transfer outside of Switzerland or to a country without an adequacy decision

Personal Data might be transferred from Switzerland to other countries within the EEA.

Nextlane – DPA – Drive DMS– September 2024
List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processings
mentioned below might be available in specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

          Name             Location                        Processing activity

 Apmatic GmbH            Switzerland         Workshop appointment on-line solution

 Solera                  Switzerland         Repair estimation and price negotiation with the
                                             insurance

 Solera                  Switzerland         Automobile technical information, maintenance,
                                             repair

 Autovista               Switzerland         Repair estimation and price negotiation with the
                                             insurance

 Auto-I                  Switzerland         Various solutions such as vehicle valuation, sales
                                             workplace, vehicle data

 Canon                   Switzerland         Electronic Document Management system

Nextlane – DPA – Drive DMS– September 2024
                      ANNEX to the Data Processing Agreement
                                  Description of ECAROS

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•    Nature of the Processing:
     Collection of Data Controller’s customers and/or prospects and/or employee’s personal data
     by the Data Controller that are integrated in the DMS of the Data Processor, with the objective
     of enhancing the services that the Data Controller can provide to its own customers and/or
     prospects.
     The Processing can relate to the sales of vehicles, after-sales activities, spare parts
     management, and accounting management depending on the type of subscription selected by
     the Data Controller. The Processing also covers the connection with relevant car
     manufacturers to provide multiple services and manage customers’ interaction.

•    Purposes of Processing are the following:

     Depending on the services subscribed by the Data Controller:
     -    Support for the Data Controller in managing its relationship with its Prospects:
          o    Management of leads
          o    Management of vehicle offers
          o    Management of marketing campaigns.
     -    Support for the Data Controller in managing its relationship with its Customers:
          o    Management of vehicle purchase
          o    Management of vehicle trade-in
          o    Organization of vehicle maintenance and test
          o    Management of parts orders and warranty with the OEM
          o    Management of courtesy vehicle
          o    Storage of administrative documents
          o    Management of marketing campaigns
          o    Publishing of Used Car pictures and information on Web sites
          o    Evaluation of vehicle value
     -        Support for the Data Controller in managing its internal organizational
          o    Workshop organization including Human resources aspects
          o    Courtesy vehicle management
          o    Management of leads
          o    Marketing campaigns
          o    Evaluation of a vehicle value.
          o    Management of Employees (timing)

Nextlane – DPA – ECAROS DMS – September 2024
Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                 Management of                             Management of Data
                                                     Management of
Data Subject categories            Prospects                               Controller’s internal
                                                      Customers
                                                                              organization
Data Controller’s Prospects                X                                         X
Data Controller’s
                                           X                  X                      X
Employees
Data Controller’s
                                                              X                      X
Customers
Data Controller’s Suppliers                                   X                      X
Car driver                                 X                  X                      X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

             Category of Personal Data                              Details

                                               Gender, name, surname, address, phone number,
   Civil Status, ID, identification data       e-mail address, ID number, driving license
                                               number, date of birth, place of birth,
   Economic and financial information          Bank account number
                                               Vehicle Identification Number, license plate,
   Information related to the vehicle
                                               insurance number

Nextlane – DPA – ECAROS DMS – September 2024
For the purpose of management of Data Controller’s Customers

         Category of Personal Data                                  Details

                                               Gender, name, surname, address, phone number,
 Civil Status, ID, identification data         e-mail address, ID number, driving license
                                               number, date of birth, place of birth
 Economic and financial information            Bank account number
                                               Vehicle Identification Number, license plate,
 Information related to the vehicle
                                               insurance number
 Other type of Personal Data                   Language, consent form

For the purpose of management of Data Controller’s internal organization

         Category of Personal Data                                  Details

                                               Gender, name, surname, address, ID number,
                                               phone number, e-mail address, driving license
 Civil Status, ID, identification data
                                               number, date of birth, place of birth, social
                                               security number
                                               Date of hire, internal employee ID, working date
 Information related to employment
                                               and absence time
 Economic and financial information            Bank account number

Contact in charge of Data Protection matter

 Data Controller                                Data Processor

 Name: [•]                                      Email address: dpo@nextlane.com
 Email address: [•]                             Postal address: 190 avenue Thiers, 69006
                                                Lyon, France
 Postal address: [•]

Location(s) of Processing operations

      - The Data Processor operates in the European Union and Switzerland.
      - The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

Nextlane – DPA – ECAROS DMS – September 2024
List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

         Name            Location                      Processing activity

 DAT                    Germany      Repair estimation, price negotiation with insurer

 Autovista              Germany      Repair estimation, price negotiation with insurer

 Datev                  Germany      Management of accounting and payroll

 Aufinity Group         Germany      Bezahl / management of digital payment

 Autoeile               Germany      Pilot to publish used vehicle and auction

 Autohauskenner         Germany      Customer satisfaction rating

 ELO Digital Office     Germany      Recording, printing, and saving documents

 VEACT                  Germany      Customer satisfaction rating

 Motorbike-Shop         Germany      Used vehicle management

 Autoscout24            Germany      Used vehicle management

Nextlane – DPA – ECAROS DMS – September 2024
                        ANNEX to the Data Processing Agreement
                                   Description of SERAUTO
Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

   •   Nature of the Processing:
       Collection of Data Controller’s customers and/or prospects and/or employee’s personal data
       by the Data Controller that are integrated in the DMS of the Data Processor, with the
       objective of enhancing the services that the Data Controller can provide to its own customers
       and/or prospects.
       The Processing can relate to the sales of vehicles, after-sales activities, spare parts
       management, and accounting management depending on the type of subscription selected
       by the Data Controller. The Processing also covers the connection with relevant car
       manufacturers to provide multiple services and manage customers’ interaction.

   • Purposes of Processing are the following:

       Depending on the services subscribed by the Data Controller:
             -   Support for the Data Controller in managing its relationship with its Prospects:
                    o Management of leads
                    o Organization of vehicle test
                    o Management of marketing campaigns.
             -   Support for the Data Controller in managing its relationship with its Customers:
                    o Management of vehicle purchase
                    o Management of vehicle trade-in
                    o Organization of vehicle maintenance and test
                    o Management of parts orders and warranty with the OEM
                    o Management of courtesy vehicle
                    o Management of vehicle registration process
                    o Storage of administrative documents
                    o Management of marketing campaigns
             -   Support for the Data Controller in managing its internal organizational
                    o Workshop organization including Human resources aspects
                    o Courtesy vehicle management
                    o Management of leads
                    o Marketing campaigns
                    o Evaluation of a vehicle value.

Nextlane – DPA – SERAUTO DMS – September 2024
Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data,
which is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                 Management of                              Management of Data
                                                     Management of
Data Subject categories            Prospects                                Controller’s internal
                                                      Customers
                                                                               organization
Data Controller’s Prospects                X                                          X
Data Controller’s
                                           X                  X                       X
Employees
Data Controller’s
                                                              X                       X
Customers
Data Controller’s Suppliers                                   X                       X
Car driver                                 X                  X                       X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

             Category of Personal Data                               Details

                                                Gender, name, surname, address, phone number,
   Civil Status, ID, identification data        e-mail address, ID number, driving license
                                                number, date of birth, place of birth,
   Economic and financial information           Bank account number
                                                Workplace and title, interest, hobbies, consent
   Other information
                                                form

Nextlane – DPA – SERAUTO DMS – September 2024
For the purpose of management of Data Controller’s Customers

            Category of Personal Data                                 Details

                                                 Gender, name, surname, address, phone number,
    Civil Status, ID, identification data        e-mail address, ID number, driving license
                                                 number, date of birth
    Economic and financial information           Bank account number, financial accounting data
                                                 Vehicle Identification Number, license plate,
    Information related to the vehicle
                                                 insurance number
    Other type of Personal Data                  Language, consent form

For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                 Details

                                                 Gender, name, surname, address, ID number,
    Civil Status, ID, identification data        phone number, e-mail address, driving license
                                                 number, date of birth, social security number
                                                 Date of hire, internal employee ID, data on sales,
    Information related to employment
                                                 commission and bonus
    Economic and financial information           Bank account number

Contact in charge of Data Protection matter

                   Data Controller                                Data Processor

    Name: [•]                                     Email address: dpo@nextlane.com
    Email address: [•]                            Postal address: 190 avenue Thiers, 69006 Lyon,
                                                  France
    Postal address: [•]

Location(s) of Processing operations

-        The Data Processor operates in the European Union, and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

Nextlane – DPA – SERAUTO DMS – September 2024
List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

          Name           Location                       Processing activity

 GT-Motiv               Spain           Repair estimation, price negotiation with insurer

 Solera                 Spain            Repair estimation, price negotiation with insurer

 Autovista              Spain           Car quotation

Nextlane – DPA – SERAUTO DMS – September 2024
                      ANNEX to the Data Processing Agreement
                                  Description of UNICAR
Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•    Nature of the Processing:
     Collection of Data Controller’s customers and/or prospects and/or employee’s personal data
     by the Data Controller that are integrated in the DMS of the Data Processor, with the objective
     of enhancing the services that the Data Controller can provide to its own customers and/or
     prospects.
     The Processing can relate to the sales of vehicles, after-sales activities, spare parts
     management, and accounting management depending on the type of subscription selected by
     the Data Controller. The Processing also covers the connection with relevant car
     manufacturers to provide multiple services and manage customers’ interaction.

•    Purposes of Processing are the following:
     Depending on the services subscribed by the Data Controller:
     -    Support for the Data Controller in managing its relationship with its Prospects:
          o  Management of leads
          o  Management of vehicle offers
          o  Organization of vehicle test
          o  Management of marketing campaigns.
     -    Support for the Data Controller in managing its relationship with its Customers:
          o  Management of vehicle purchase
          o  Management of vehicle trade-in
          o  Organization of vehicle maintenance and test
          o  Management of parts orders and warranty with the OEM
          o  Management of courtesy vehicle
          o  Management of vehicle registration process
          o  Storage of administrative documents
          o  Management of marketing campaigns
          o  Publishing of used car pictures and information on web sites
          o  Evaluation of a vehicle value
     -    Support for the Data Controller in managing its internal organizational
          o  Workshop organization including Human resources aspects
          o  Courtesy vehicle management
          o  Time recording
          o  Sales related commissions and incentives
          o  Control of IT access and IT usage monitoring.

Nextlane – DPA – UNICAR DMS – September 2024
Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided for by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                 Management of                             Management of Data
                                                     Management of
Data Subject categories            Prospects                               Controller’s internal
                                                      Customers
                                                                              organization
Data Controller’s Prospects                X                                            X
Data Controller’s
                                           X                  X                         X
Employees
Data Controller’s
                                                              X                         X
Customers
Data Controller’s Suppliers                                   X                         X
Car driver                                 X                  X                         X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

             Category of Personal Data                              Details

                                               Gender, name, surname, address, phone number,
   Civil Status, ID, identification data       e-mail address, ID number, driving license
                                               number, date of birth
   Economic and financial information          Bank account number
   Other information                           Workplace and title, interest, hobbies

Nextlane – DPA – UNICAR DMS – September 2024
For the purpose of management of Data Controller’s Customers

            Category of Personal Data                                Details

                                                Gender, name, surname, address, phone number,
    Civil Status, ID, identification data       e-mail address, ID number, driving license
                                                number, date of birth
    Economic and financial information          Bank account number, financial accounting data
                                                Vehicle Identification Number, license plate,
    Information related to the vehicle
                                                insurance number

For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                Details

                                                 Gender, name, surname, address, ID number,
    Civil Status, ID, identification data        phone number, e-mail address, driving license
                                                 number, date of birth
                                                 Date of hire, internal employee ID, working and
    Information related to employment            absence data, data on sales, commission and
                                                 bonus, data on IT access control and IT usage
    Economic and financial information           Bank account number

Contact in charge of Data Protection matter

                   Data Controller                               Data Processor

    Name: [•]                                     Email address: dpo@nextlane.com
    Email address: [•]                            Postal address: 190 avenue Thiers, 69006 Lyon,
                                                  France
    Postal address: [•]

Location(s) of Processing operations

-        The Data Processor operates in the European Union and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

Nextlane – DPA – UNICAR DMS – September 2024
List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the Subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

         Name            Location                      Processing activity

 DAT                    Germany      Repair estimation, price negotiation with insurer

 Autovista              Germany      Repair estimation, price negotiation with insurer

 Datev                  Germany      Management of accounting and payroll

 ELO Digital Office     Germany      Recording, printing, and saving documents

 VEACT                  Germany      Customer satisfaction rating

 Motorbike-Shop         Germany      Used vehicle management

 Autoscout24            Germany      Used vehicle management

Nextlane – DPA – UNICAR DMS – September 2024
                          ANNEX to the Data Processing Agreement
                                      Description of Europlus

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing
•       Nature of the Processing:
        Collection of Data Controller’s customers personal data by the Data Controller that are
        integrated in the Solution of the Data Processor, with the objective of enhancing the services
        that the Data Controller can provide to its own customers.
        The processing can relate to the sales of vehicles, after-sales activities, spare parts and repair
        management, depending on the type of subscription selected by the Data Controller. The
        Processing also covers the connection with relevant car manufacturers to provide multiple
        services and manage customers’ interaction.

•   Purposes of Processing are the following:

    Depending on the services subscribed by the Data Controller:
        -     Support for the Data Controller in managing its relationship with its customers:
            o      Management of vehicle purchase
            o      Management of vehicle trade-in
            o      Organization of vehicle maintenance and test
            o      Organization of marketing campaigns
            o      Management of parts orders and warranty with the OEM
            o      Management of courtesy vehicle
            o      Storage of administrative documents.
    -         Support for the Data Controller in managing its internal organization:
            o      Workshop organization
            o      Courtesy vehicle management
            o      Time recording

Retention period

The Data Controller shall provide to the Data Processor the retention policy of Personal Data, which
is aligned with the principles provided by Applicable Law.

Nextlane – DPA – EUROPLUS DMS – September 2024
Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                                                     Management of Data
                                           Management of
  Data Subject categories                                            Controller’s internal
                                            Customers
                                                                        organization
  Data Controller’s employees                       X                            X
  Data Controller’s customers                       X                            X
  Data Controller’s suppliers                       X                            X
  Car driver                                        X                            X

Categories of Personal Data

Personal Data processed relates to the following categories:

For the purpose of management of Data Controller’s customers

         Category of Personal Data                                    Details

 Civil Status, ID, identification data related Gender, name, surname, address, phone number,
 to Customers/drivers                          e-mail address, date of birth.
                                                 Vehicle Identification Number, license plate,
 Information related to the vehicle
                                                 insurance number
                                                 Language, consent form, financial accounting
 Other type of Personal Data
                                                 data

For the purpose of management of Data Controller’s internal organization

         Category of Personal Data                                     Details

                                                 Gender, name, surname, address, phone number,
 Civil Status, ID, identification data           e-mail address, date of birth, place of birth, place
                                                 of birth
                                                 Date of hire, internal employee ID, working date
 Information related to employment
                                                 and absence time
 Economic and financial information              Bank account number

Nextlane – DPA – EUROPLUS DMS – September 2024
Contact in charge of Data Protection matter

                    Data Controller                           Data Processor

    Name: [•]                                    Email address: dpo@nextlane.com
    Email address: [•]                           Postal address: 190 avenue Thiers, 69006
                                                 Lyon, France
    Postal address: [•]

Location(s) of Processing operations

-       The Data Processor operates in the European Union and Switzerland.
-       The Data Controller operates in __________________

Data transfer outside of the EEA and/or of Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depends on the one hand on the add-
ons subscribed by the Data Controller, and on the other hand, on the contracts that the Data
Controller has with the vehicle manufacturers. In addition, some of the subsequent processing
mentioned below might be available on specific countries.

Therefore, the DPA will be updated based on the information provided by the Data Controller.

As an illustration purpose, only the main Subsequent Data Processors are:

             Name            Location                    Processing activity

    Apmatic GmbH            Switzerland   Workshop appointment on-line solution

    Auto-I                  Switzerland   For various solutions they provide like vehicle
                                          valuation, sales workplace, vehicle data

    Nextlane                Switzerland   Connection with Drive – for internal organization
    Switzerland                           processing

    Nextlane                Switzerland   Premium Finance as accounting module
    Switzerland

Nextlane – DPA – EUROPLUS DMS – September 2024
                        ANNEX to the Data Processing Agreement
                            Description of CRMAuto After Sales

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•     Nature of the Processing:
      The Processing covers the relationship between an OEM (the Data Controller) and its dealer
      network.
      The Processing can relate to the workshop network’s activities, like import of vehicle data,
      multimedia damage report, band management tools vehicle conditions video check, and online
      appointments management.

•     Purposes of Processing are the following:
      Depending on the services subscribed by the Data Controller:
      -   Support for the Data Controller in managing its relationship with its Customers/Network
          dealers:
          o      Organization of vehicle maintenance
          o      Organization of vehicle test
          o      Management of courtesy vehicle
          o      Storage of administrative documents
          o      Publication of used car pictures and information on Web Site.
      -   Support for the Data Controller in managing its internal organizational
          o      Workshop organization
          o      Courtesy vehicle management

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Nextlane – DPA – CRMAuto After Sales – September 2024
Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                                                            Management of Data
                                 Management of          Management of
 Data Subject categories                                                    Controller’s internal
                                   prospects             customers
                                                                               organization

Data Controller’s Prospects                X                                           X
Data Controller’s
                                                              X                        X
Customers
Data Controller’s
                                           X                  X                        X
Employees
Others: car driver                         X                  X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

           Category of Personal Data                                 Details

                                                 Gender, name, surname, address, phone number,
   Civil Status, ID, identification data         e-mail address, ID number, driving license
                                                 number, date of birth

For the purpose of management of Data Controller’s Customers

           Category of Personal Data                                  Details

                                                 Gender, name, surname, address, phone number,
  Civil Status, ID, identification data          e-mail address, ID number, driving license
                                                 number, date of birth
  Information related to the vehicle             Vehicle Identification Number, license plate
  Others                                         Insurance number, language

Nextlane – DPA – CRMAuto After Sales – September 2024
For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                   Details

                                                   Gender, name, surname, address, phone number,
    Civil Status, ID, identification data          e-mail address, ID number, driving license
                                                   number, date of birth, place of birth
    Information related to employment              Date of profile creation in the Processing

Contact in charge of Data Protection matter

                   Data Controller                                   Data Processor

    Name: [•]                                       Email address: dpo@nextlane.com
    Email address: [•]                              Postal address: 190 avenue Thiers, 69006 Lyon,
                                                    France
    Postal address: [•]

Location(s) of Processing operations

-        The Data Processor operates in the European Union and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA, and/or Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depend on the add-ons subscribed to
by the Data Controller. In addition, some of the subsequent processing mentioned below might be
available in specific countries.
Therefore, the DPA will be updated based on the information provided by the Data Controller.
As an illustration purpose, only the main Subsequent Data Processors are:

           Name               Location                  Subsequent Data Processing

    Uanataca                Spain            Electronic signature provider

    Labsmobile              Spain            SMS provider for Digital signature process

    360 Learning            France           Academy (training)

    Nextlane Spain          Spain           Imabox (uploaded images)

Nextlane – DPA – CRMAuto After Sales – September 2024
                        ANNEX to the Data Processing Agreement
                               Description of CRMAuto Sales

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•     Nature of the Processing:
      The Processing covers the relationship between an OEM (the Data Controller) and its dealer
      network.
      The Processing can relate to the customization of new vehicles, an interactive offer,
      management of used vehicles, tools of the Data Controller’s brands, the management of fleet
      order, and management of leads.

•     Purposes of Processing are the following:
      depending on the services subscribed by the Data Controller:
     -       Support for the Data Controller in managing its relationship with its Prospects:
             o    Management of leads
             o    Management of vehicle offers
             o    Organisation of vehicle test
             o    Management of marketing campaigns.
      -      Support for the Data Controller in managing its relationship with its Customers/Network
             dealers:
             o     Management of vehicle purchase
             o     Management of vehicle trade-in
             o     Organization of vehicle test
             o     Management of courtesy vehicle
             o     Management of registration process of the vehicle
             o     Storage of administrative documents
             o     Management of marketing campaigns.
      -      Support for the Data Controller in managing its internal organizational
             o    Courtesy vehicle management
             o    Management of leads
             o    Management of marketing campaigns.

Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Nextlane – DPA – CRMAuto Sales – September 2024
Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                Management of                                 Management of Data
                                                        Management of
Data Subject categories           Prospects                                   Controller’s internal
                                                         Customers
                                                                                 organization
Data Controller’s prospects              X                                              X
Data Controller’s
                                                                X                       X
customers
Data Controller’s                        X
                                                                                        X
employees

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects

        Category of Personal Data                                      Details

                                                  Gender, name, surname, address, phone number, e-
 Civil Status, ID, identification data            mail address, ID number, driving license number,
                                                  date of birth.

For the purpose of management of Data Controller’s Customers

         Category of Personal Data                                      Details

                                                   Gender, name, surname, address, phone number,
 Civil Status, ID, identification data             e-mail address, ID number, driving license
                                                   number, date of birth.
 Information related to the vehicle                Vehicle Identification Number, license plate,

Nextlane – DPA – CRMAuto Sales – September 2024
For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                        Details

                                                     Gender, name, surname, address, phone number,
    Civil Status, ID, identification data            e-mail address, ID number, driving license
                                                     number, date of birth, place of birth
    Information related to employment                Date of profile creation in the Processing

Contact in charge of Data Protection matter

                   Data Controller                                    Data Processor

    Name: [•]                                         Email address: dpo@nextlane.com
    Email address: [•]                                Postal address: 190 avenue Thiers, 69006 Lyon,
                                                      France
    Postal address: [•]

Location(s) of Processing operations

-        The Data Processor operates in the European Union and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA and/or Switzerland or to a country without an adequacy
decision

Non applicable

List of Subsequent Data Processors

The Subsequent Data Processors used by the Data Processor depend on the add-ons subscribed to
by the Data Controller. In addition, some of the subsequent processing mentioned below might be
available in specific countries.
Therefore, the DPA will be updated based on the information provided by the Data Controller.
As an illustration purpose, only the main Subsequent Data Processors are:

           Name              Location                    Subsequent Data Processing

    Uanataca                Spain            Electronic signature provider

    Labsmobile              Spain           SMS provider for Digital signature process

    360 Learning            France           Academy (training)

    Nextlane Spain          Spain            Imabox (uploaded images)

Nextlane – DPA – CRMAuto Sales – September 2024
                        ANNEX to the Data Processing Agreement
                               Description of KOBRA II CRM

Controller

The Data Controller is the Customer of Nextlane.

Nature and purpose of Processing

•    Nature of the Processing:
     Collection of Data Controller’s customers and/or employee’s personal data by the Data
     Controller that are integrated in the CRM of the Data Processor, with the objective of
     enhancing the services that the Data Controller can provide to its own customers, on the
     Swedish automotive market.
     The Processing can relate to the sales of vehicles depending on the type of subscription
     selected by the Data Controller. The Processing covers the connection with relevant car
     manufacturers and integrations to other solutions, platforms and to Kobra II DMS, facilitating
     comprehensive dealership management, to provide multiple services and manage end-
     customers’ interaction.

•    Purposes of Processing are the following:
     depending on the services subscribed by the Data Controller:
     -       Support for the Data Controller in managing its relationship with its Prospects:
             o    Management of vehicle purchase
             o    Management of vehicle trade-in
             o    Management of vehicle buy-in
             o    Management of VDN
             o    Management of parts orders and warranty with the OEM
             o    Management of courtesy vehicle
             o    Storage of administrative documents.
     -       Support for the Data Controller in managing its relationship with its customers:
             o    Management of vehicle purchase
             o    Management of vehicle trade-in
             o    Management of vehicle buy-in
             o    Management of VDN
             o    Management of parts orders and warranty with the OEM
             o    Management of courtesy vehicle
             o    Storage of administrative documents.
     -       Support for the Data Controller in managing its organization:
             o    Management of logging access rights of employees to the CRM

Nextlane – DPA – KOBRA II CRM – September 2024
Retention period

The Data Controller shall provide to the Data Processor the retention policy of personal data, which
is aligned with the principles provided by Applicable Law.

Categories of Data Subjects

The Personal Data processed by the Data Processor are related to the following categories of Data
Subjects:

                                                                                  Management of
                                      Management of              Management of
Data Subject categories                                                              internal
                                        Prospects                 Customers
                                                                                   organisation
Data Controller Prospects                     X
Data Controller’s Employees                   X                       X                   X
Data Controller’s customers                                           X
Data Controller’s Suppliers                   X                       X
Car drives                                    X                       X

Categories of Personal Data

Personal Data processed relate to the following categories:

For the purpose of management of Data Controller’s Prospects:

         Category of Personal Data                                    Details

 Civil Status, ID, identification data related Name, surname, address, phone number, e-mail
 to Customers/drivers                          address, ID number, date of birth.
 Other type of Personal Data                      Consent form

For the purpose of management of Data Controller’s Customers

         Category of Personal Data                                    Details

 Civil Status, ID, identification data related Name, surname, address, phone number, e-mail
 to Customers/drivers                          address, ID number, date of birth.
 Other type of Personal Data                      Consent form

Nextlane – DPA – KOBRA II CRM – September 2024
For the purpose of management of Data Controller’s internal organization

            Category of Personal Data                                Details

    identification data (login)                  Name, surname, phone number, e-mail address

Contact in charge of Data Protection matter

                   Data Controller                               Data Processor

    Name: [•]                                     Email address: dpo@nextlane.com
    Email address: [•]                            Postal address: 190 avenue Thiers, 69006 Lyon,
                                                  France
    Postal address: [•]

Location(s) of Processing operations

-        The Data Processor operates in the European Union and Switzerland.
-        The Data Controller operates in __________________

Data transfer outside of the EEA and/or Switzerland or to a country without an adequacy
decision

Not applicable

List of Subsequent Data Processors

           Name              Location                   Processing activity
Nextlane Sweden AB         Sweden        Integration to Kobra II DMS
Bilvision                  Sweden        Change of ownership, Customer/Vehicle information
Bisnode/Infotorg           Sweden        "Driving license check (CBR)”
Toyota-finans, DNB,        Sweden        Financing for credit application
Santander
IF Försäkringar            Sweden        Insurance
CSig                       Sweden        Digital signature of contracts
SA3                        Sweden        For BMW's brand : order of car and the selection of
                                         accessories
Toyota VOM                 Sweden        New car orders
Mercedes CAS/CSL           Sweden        Follow up of transactions containing Leads

Leads                      Sweden        TO LQ MB XS JA LR - Transactions containing Leads
                                         are sent from and to KSS for follow-up

Nextlane – DPA – KOBRA II CRM – September 2024