You can also call and leave your message anonymously via our telephone answering service provided by WhistleB. Leave your message after the tone. Finish with hash key (#). Please be advised that, in proceeding with this call you are consenting to your message being recorded. Your voice will be anonymised.

In-country phone numbers:

• Austria: 0800-298001
• Belgium: 0800-78559 (French/English), 0800-79651 (Dutch/English)
• Denmark: 802-53633
• France: 0800-916095
• Germany: 0800-1810898
• Italy: 800-789930
• Japan: 06-4580-8420 
• Korea, Republic of South: 007-981 42074762
• Netherlands: 0800-7700020
• Norway: 800-13059 
• Sweden: 08-42003154
• Switzerland: 0800-848131
• United Arab Emirates: 800 0178170
• United Kingdom: 0207-6601375
• United States: 1800-218-8954 (English), 1855-666-3210 (Spanish)

Organisation codes:

• Lotus Technology Innovative Limited – UK: 809340
• Lotus Cars Europe B.V. and its subsidiaries – Europe: 809341
• Lotus Cars Limited - UK and US: 809342

Once you leave your message, you will receive a personal code should you wish to follow up. When you call to follow up, you will need to enter your personal code, then you will be able to listen to any response from us and leave a new message if needed.

PRIVACY NOTICE

Lotus Technology Innovative Limited having its trading address at 18 Vine Hill, London, EC1R 5DZ, registration number 13337498 is the subsidiary UK entity of Lotus Technology Inc. This privacy notice relates to Lotus Technology Innovative Limited and its affiliates and subsidiaries, which for the avoidance of doubt includes:

• Lotus Cars Europe B.V., having its trading address at Johan Huizingalaan 400a, 1066 JS, Amsterdam, Netherlands, registration number 83355235, and its subsidiaries:
• Lotus Cars Austria GmbH
• Lotus Cars Germany GmbH
• Lotus Cars Switzerland GmbH
• Lotus Cars Netherlands B.V. 
• Lotus Cars Italy Srl
• Lotus Cars Denmark ApS
• Lotus Cars Sweden AB
• Lotus Cars Norge AS
• Lotus Cars Belgium B.V.
• Lotus Cars France SAS
  
  
• Lotus Cars Limited, having its trading address at Potash Lane, Hethel, Norwich, Norfolk, NR14 8EZ, registration number 00895081; and
• Lotus Cars USA Inc, having its trading address at 35255 Glendale, Livonia, Michigan 48150, USA, company identification number 801068877

(together “LOTUS”).

LOTUS respects your privacy and is committed to protecting your personal data. LOTUS is committed to protecting the identity of whistleblowers who choose to remain anonymous and ensuring that the contents of the whistleblowing reports and the people that are mentioned within the report, are treated carefully and sensitively.  

This privacy notice will inform you as to how we look after your personal data when you visit https://report.whistleb.com/en/lotus (referred to as “our website” or “the website” in this privacy notice) or when you contact the Interactive Voice Respond (“IVR”) telephone line, (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how LOTUS collects and processes your personal data through your use of this website, including any data you may provide through this website or the IVR when you submit a report.

This website is not intended for children and we do not knowingly collect data relating to children unless your whistleblowing report relates to them.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

WHO WE ARE

LOTUS is the controller and responsible for your personal data (collectively referred to as “LOTUS”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy committee that is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the relevant legal department accordingly:

Entity to which report relates

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Lotus Technology Innovative Limited - UK
Email address: LTIL.DataProtection@eu.lotuscars.com

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Lotus Cars Europe B.V. and its subsidiaries - Europe
Email address: privacy@eu.lotuscars.com

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Lotus Cars Limited - UK
Email address: legal@lotuscars.com

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Lotus Cars USA Inc. - US
Email address: legal@lotuscars.com

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You have the right to make a complaint at any time to your local regulatory authority for data protection issues, for example to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

When you submit a report, you can choose to remain anonymous by not providing your name or contact details. The only information that we will receive is the information that you provide explicitly within the report questionnaire.

Depending on the data that you submit to us in the report, we may collect, use, store and transfer different kinds of personal data about you, or individual(s) you are providing a report about which we have grouped together as follows:

• Identity data such as first name, last name, username or similar identifier, or title;
• Contact data such as address, email address and telephone numbers;
• The nature of your relationship with LOTUS, such as whether you are an employee, former employee, occasional employee, supplier or subcontractor;
• Any personal data provided within the optional attachments or free text fields;
• Special Categories of Personal Data (this includes details about your or the individual(s) you are providing a report about, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data);
• Information about criminal convictions and offences.

We may also put your personal data into aggregated and anonymised form. Once anonymised, that data is no longer your personal data. However, if we combine or connect that anonymised, aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We collect data from you only through the Direct interactions. We only collect the data that you explicitly provide to us, either:

• in the report questionnaire on the website, or
• by telephone, via the IVR.

When you enter data into the report questionnaire, WhistleB does not collect your IP address or metadata associated with any documents submitted.  When you submit a report verbally over the IVR phone line, your voice is anonymised.

4. HOW WE USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the data of others within your report, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity - Lawful basis for processing including basis of legitimate interest

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 To comply with our legal obligations regarding whistleblowing such as under the Whistleblowing Directive (EU) 2019/1937 - Legal obligation

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To evaluate and investigate whistleblowing reports - Legal obligation

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To inform relevant stakeholders within LOTUS of issues raised in your report - Legitimate interest

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To share the contents of the report with internal and external professional advisors in the context of an investigation or risk assessment - Legitimate interest and legal obligation

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To report potential wrongdoings to the relevant regulatory or judicial authorities - Legal obligation

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To create statistics to analyse the efficacy of LOTUS’ whistleblowing investigation procedure - Legitimate interest

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To store the report for the requisite retention period - Legal obligation

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5. DISCLOSURES OF YOUR PERSONAL DATA

Your report will be received and assessed by a Case Manager. If this Case Manager assesses that it is necessary to escalate your report, details of the report (which may include personal data) may be shared with the parties set out below for the purposes set out in the table above.

• Audit Committee and the Board of Directors of Lotus Technology Inc and other relevant LOTUS management stakeholders;
• Professional advisers including lawyers, bankers, auditors, intermediaries and insurers who provide consultancy, banking, legal, insurance and accounting services;
• Regulatory or judicial authorities;
• IT service providers, providing system administration, hosting and support services in the event of cyber-related breaches.

In addition, we may share details of the report to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We will not share information identifying the whistleblower without the explicit consent of the whistleblower.

6. INTERNATIONAL TRANSFERS

Your Personal Data will be processed and hosted by WhistleB within the European Union.

Your report and any subsequent exchanges with the Case Managers may be transferred to the European Union if you are located in a non-EU country.

We may transfer your personal data to countries outside the UK or the EU. A transfer of personal data to a country outside the UK or EU may occur for the legitimate purposes mentioned above.

Please note that not all countries have a data protection level recognized as adequate by the ICO or the European Commission. For data transfers to countries outside the EU or the UK, we will ensure that the recipient applies the same standard of data protection before transferring any personal data. (e.g. through an agreement with the recipient containing the so-called “International Data Transfer Agreement” issued by the ICO, the “EU standard contractual clauses” of the European Union or other appropriate safeguards). You can obtain further details of our safeguards by contacting us.

7. DATA SECURITY

We have put in place appropriate protective measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed:

a. There are a limited number of Case Managers. Case Managers are bound by a strict duty of confidentiality and have been given appropriate training to follow when handling your report.

b. If your report is escalated and shared with additional parties, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

c. In order to protect the identity of whistleblowers who choose to remain anonymous, when submitting a report, you will be assigned a username and password by the website which you can use to log in to the system and communicate with the Case Managers directly, without having to provide personal contact details.

d. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

WhistleB prioritises data privacy and adheres to ISO 27001 Information Security Standards. For more information about WhistleB’s data and privacy measures, please visit: https://www.navex.com/en-gb/products/navex-ethics-compliance/whistleb-whistleblowing-system/data-privacy-security/

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, including SOX. We may retain your personal data for a longer period if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we follow regulatory requirements and consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. YOUR LEGAL RIGHTS

Under data protection law, you have rights in relation to your personal data:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances.
• Object to processing of your personal data where we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Object to processing your personal data for direct marketing purposes.
• Request restriction of processing of your personal data in certain circumstances.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us via the following email addresses:

• LTIL.DataProtection@eu.lotuscars.com in relation to Lotus Technology Innovative Limited
  
  
• Legal@lotuscars.com in relation to Lotus Cars Limited
  
  
• privacy@eu.lotuscars.com in relation to Lotus Cars Europe B.V. and its subsidiaries; or
  
  
• Legal@lotuscars.com in relation to Lotus Cars USA Inc.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10. ANNEX A: LIST OF THIRD-PARTY PROCESSORS

WhistleBWhistleblowing Centre AB