Volkswagen ID Privacy Policy
This Privacy Policy contains important information on your rights in conjunction with the processing of your personal data and the legal grounds on which basis the processing of the personal data we collect in the context of use of the Volkswagen ID, or which you provide to us, takes place. We do not intend to collect data from children.
Please note that we – as a German company – are bound by German law including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (‘GDPR’), including when we process personal data concerning people whose permanent residence is outside of Germany. The information required in accordance with German law and the GDPR regarding the processing of your personal data can be found in Part I of this Privacy Policy. We may also be bound by national laws from other countries to a certain degree. If you have your permanent residence in a country named in Part II of this Privacy Policy, you will find more information therein.
Part I
A.Data controller
This Privacy Policy contains information regarding the processing of your personal data by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, email: vw@volkswagen.de entered in the Register of Companies at the District Court of Braunschweig under number HRB 100484 (‘Volkswagen AG’, ‘we’, ‘our’ or ‘us‘), in the context of use of the central user account ‘Volkswagen ID’ (‘Volkswagen ID’).
For processing in accordance with this Privacy Policy and unless otherwise agreed with you, we are what is known as the ‘data controller’ as defined by the GDPR for the processing of personal data. We are the ‘data controller’ as we decide on the purposes and means of processing this personal data.
B. Processing of your personal data
I. Processing of log data on the website
If you only visit the Volkswagen ID landing page without registering or logging in, we only process the following log data concerning you:
-IP address,
-the operating system and web browser you use and your screen resolution setting, and
-the date and time of your visit.
We process this data on the basis of Article 6, paragraph 1, letter f GDPR on the grounds of our legitimate interest in properly displaying the website to you. The log data is stored for a month. This personal data is deleted thereafter.
II. Cookies
We use various cookies on our websites. Cookies are small files containing configuration information which are stored on your device. In essence, cookies can be split into three categories. Some cookies are essential for website functionality (known as functional cookies), some cookies make a website easier to use and save settings such as your language preferences (known as convenience cookies) and some cookies are used to create a pseudonymised user profile (known as tracking cookies).
The functional cookies need to be processed to allow you to visit the website (Article 6, paragraph 1, letter b GDPR). You can find more information on our cookies below.
Cookie name | Purpose | Storage period | Cookie type |
---|---|---|---|
identity-kit-access-token | This cookie allows access to profile data. | 1 hour | Permanent or protocol cookie |
identity-kit-access-token-expiration | This cookie defines how long the access token remains valid. | Until the end of the session | Session cookie |
identity-kit-id-refresh-token | This cookie renews the access token once it has expired. | Until the end of the session | Session cookie |
identity-kit-id-state | These cookies are unique identifiers to protect against CSRF attacks. | Until the end of the session | Session cookie |
identity-kit-id-token | This cookie is used for user identification. | Until the end of the session | Session cookie |
identity-kit-user-email | This cookie saves the user’s email address, which is required for some functions in the Volkswagen ID portal. | Until the end of the session | Session cookie |
referer-location | This cookie temporarily stores the user’s destination URL so that they return there after authentication. | Until the end of the session | Session cookie |
III. Registration and use of Volkswagen ID
1.To create a Volkswagen ID, you need to register with an email address and password. To verify your registration for the Volkswagen ID, we use what is known as the ‘double opt-in’ procedure. An email will be sent to you at the email address provided requesting you to confirm. Data is processed on the basis of contract fulfilment (providing the ‘Volkswagen ID’ service, Article 6, paragraph 1, letter b GDPR).
2.In the Volkswagen ID, you can also voluntarily provide additional personal data beyond the obligatory email address and password fields, which is then stored by us in your Volkswagen ID so that this data can be transferred, with your separate consent, to services you log into with your Volkswagen ID (see B.III.3.):
-name,
-salutation and title,
-date of birth,
-address,
-telephone numbers,
-preferred language,
-profile picture.
If you do not provide this additional information or you supply inaccurate information, it may not be possible for you to use other digital services in conjunction with your Volkswagen ID, if the information is required to use another such digital service. However, your ability to set up a Volkswagen ID will not be affected. This data is saved in the Volkswagen ID on the basis of contract fulfilment (providing the ‘Volkswagen ID’ service, Article 6, paragraph 1, letter b GDPR).
3.You may use your Volkswagen ID to log into various services (such as websites or other digital services), which may be provided by us or also by third parties. The first time you log in, you will be asked to give your consent (Article 6, paragraph 1, clause 1, letter a GDPR) to the processing and/or transfer of the data required to provide the service from the Volkswagen ID. If Volkswagen AG provides services on an ongoing basis in exchange for payment of remuneration and you thereby enter into an ongoing commitment, the access to personal data in your Volkswagen AG is based on contractual grounds (Article 6, paragraph 1, letter b GDPR), after you have authorised the service to access this data.
4.You can log in to selected Volkswagen partners in Germany with your Volkswagen ID using a QR code. Once you have logged in, you may consent to the transfer of data from the Volkswagen ID to the Volkswagen partner (Article 6, paragraph 1, letter a GDPR). In the event that you consent, Volkswagen AG transmits data saved in the Volkswagen ID (such as first name, surname, email address, address, telephone number, language and birthday) and saved configurations to the partner for the purpose of customer support and creation and delivery of personal offers and invoices. You may also consent to the transfer of data stored during the sales process to Volkswagen AG (Article 6, paragraph 1, letter a GDPR). In the event that you give your consent, the Volkswagen partner transfers the data stored during the sales process (such as first name, surname, email address, address, telephone number, language and birthday) and saved configurations to Volkswagen AG for the purposes of completing your Volkswagen ID user account. Volkswagen AG will notify you of the transfer via email and ask you for confirmation. In the event of confirmation via a link contained in the email, Volkswagen AG shall store the data in your Volkswagen ID user account.
For more information, please see the Privacy Policy for the Volkswagen partner named in your consent.
You may of course withdraw your abovementioned consent (Article 6, paragraph 1, letter a GDPR) at any time, without giving reasons, with immediate effect for the future, with respect to the Volkswagen partner via the given contact details or with respect to Volkswagen AG, e.g. by email to info-datenschutz@volkswagen.de, via the contact details stated in the Site notice or in the Volkswagen ID user account. If you withdraw your consent, Volkswagen AG and the Volkswagen partner shall no longer process your personal data for the above purposes. However, said withdrawal does not affect the lawfulness of data processing prior to withdrawal.
5.You may delete the Volkswagen ID in its entirety in the menu option ‘Account settings’. If you do this, we shall delete your personal data, if and insofar as we are not obliged to store the data on other grounds (particularly for grounds pertaining to trade or fiscal law). In that event, the data will be deleted as soon as these grounds cease to exist. If the data is still required to settle claims arising from contracts with us, it shall not be deleted until these claims have been settled.
6.You may (with the exception of your email address and password) also delete all or individual items of personal data from the Volkswagen ID, without deleting the entire Volkswagen ID. However, this does not affect the processing of personal data for the purposes of a service if you have granted it authorisation for access and personal data has therefore already been transferred to the service. The processing of your data in conjunction with the specific service is governed by the Privacy Policy for the service in question.
7.You may also withdraw authorisation to access your personal data for individual or all services you have logged into with your Volkswagen ID. If Volkswagen AG provides services on an ongoing basis in exchange for payment of remuneration, the withdrawal of authorisation of data access may be made conditional upon the contract for the provision of services being terminated first; for services provided by third parties, this limitation does not exist. Withdrawal of authorisation of data access only has effect for the future. In the context of use of a service, data already transferred to the service may continue to be processed by the service if necessary. You can find information on this in the service's Privacy Policy. You will find an overview of the services you have logged into with your Volkswagen ID in your Volkswagen ID portal. You can also manage your authorisations there.
IV. Dialogue Centre (customer services)
1.You can contact our Dialogue Centre by email or telephone. If you contact our Dialogue Centre, the information and data you provide (including personal data) shall be recorded digitally so that your enquiry can be dealt with. If you do not provide this information, we might be unable to process your enquiry.
2.If you contact our Dialogue Centre by telephone, you will be asked for the following data at a minimum: surname, first name, email address, telephone number, place of residence (country) and language.
3.If you contact our Dialogue Centre by email, the following data shall be collected at a minimum: email address, place of residence (country) and language.
4.We may ask for further information depending on the matter in question. This information includes:
-data regarding your smartphone (operating system and operating system version),
-data regarding your browser (browser and browser version),
-data regarding the use of the Volkswagen ID (set language),
-data regarding your vehicle (vehicle identification number (VIN)),
-Information on your enquiry (what is the problem? What led to the problem?
What is the effect of the problem? Does the problem recur or did it only occur once? When did the problem first occur?).
5.The processing of your personal data in the context of customer service by us takes place for the purposes of the fulfilment of a contract to which you are a party, or is required in order to take steps at your request prior to entering into a contract (Article 6, paragraph 1, letter b GDPR).
6.We store your data only for as long as necessary for the respective stated purposes for which we process your data. The relevant retention period may range from three months (e.g. for simple queries or complaints) or five years (e.g. for claims indicating a dispute) to up to 10 years (e.g. for claims for damages in conjunction with ‘production certificates’).
V. Processing for the purposes of advertising from Volkswagen AG
To receive advertising personally tailored to you from us by email and/or telephone, you may consent to the relevant processing of your data for this purpose (Article 6, paragraph 1, letter a GDPR). In that event, the following data is processed once you have given your consent:
-private contact and identification data (e.g. surname, first name, email address, telephone number)
-transaction data (e.g. parking sessions completed)
-vehicle usage data (e.g. logbook, fill levels)
-contract data (e.g. vehicle equipment, ongoing contracts for services)
-IT usage data (e.g. last logins to services)
-campaign data (e.g. time and content of recent campaign delivery)
This data is processed for the following purposes:
-market research and personally tailored advertising for new and existing products (e.g. digital products),
-discount offers,
-service and loyalty programmes,
-delivery of customer magazines (including, for instance, information on vehicles and vehicle-related products and services, including updates on technical innovations, digital products and services for your vehicle (e.g. Volkswagen Connect), accessories, customer and product events, trade fairs and other events)
To better adapt the content of our emails to your needs, we also process, on the basis of your consent (Article 6, paragraph 1, clause 1, letter a GDPR), personal data concerning you regarding your usage behaviour on receipt of advertising and market research (opening emails and links within emails). The opening of links or advertising from a specific area is detected and stored. We use this information to work out which topics are of interest to you. On that basis, you will receive advertising better suited to your usage behaviour in future.
If you withdraw your consent, your personal data shall no longer be processed for the purposes of advertising and market research. You may withdraw your consent by clicking on the ‘Unsubscribe’ link contained in the messages or by sending us an email to datenschutz@volkswagen.de. You may also withdraw your consent directly in your Volkswagen ID portal.
If you withdraw your consent, we shall no longer process your personal data for advertising purposes.
We shall also cease to process your personal data for these purposes if we have not contacted you for advertising purposes for a year.
VI. Processing for the purposes of advertising by the national sales company (importer) responsible for your country *
*This section does not apply to people permanently resident in Germany
If you wish to receive advertising personally tailored to you from the national sales company (importer) responsible for your country, you must consent to the processing of your data for this purpose (Article 6, paragraph 1, letter a GDPR). If you give your consent, Volkswagen AG processes personal data from the Volkswagen ID user account and associated services. The following data is processed once you have given your consent:
-private contact and identification data (e.g. surname, first name, email address, telephone number)
-personal details (such as preferred partners)
-transaction data (e.g. parking sessions completed)
-vehicle data (e.g. built-in navigation system in stored vehicles)
-vehicle usage data (e.g. logbook, fill levels)
-contract data (e.g. ongoing contracts with associated services)
-IT usage data (e.g. last logins to services, use of functions)
-campaign data (e.g. time and content of recent campaign delivery)
This data is processed for the following purposes:
Surveys and personally tailored advertising such as information, offers, discounts on new and existing products from the national sales company (importer) responsible for your country (e.g. vehicles and vehicle-related products), products from Volkswagen Group Charging GmbH (e.g. the Elli charging card) and products from national subsidiaries of Volkswagen Financial Services AG (e.g. leasing) and information on and invitations to service and loyalty programmes, delivery of customer magazines, customer and product events (e.g. test drives, product launches, product demonstrations), trade fairs and events.
In order to improve its advertising, Volkswagen AG pseudonymises and segments the personal data stored in your Volkswagen ID user account and associated services. If you have consented to advertising (Article 6, paragraph 1, letter a GDPR), Volkswagen AG uses the results of segmentation and makes a direct personal link with the data mentioned above. For more information on the pseudonymisation and segmentation of your data, please see the section ‘Segmentation for the purposes of advertising optimisation’ in the Privacy Policy for the service you are using. You can find services you use and which are linked to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
For the purposes of approaches by the national sales company (importer) responsible for your country, Volkswagen AG transfers relevant data (e.g. contact information) and results of relevant segmentation to the national sales company (importer) responsible for your country. The national sales company (importer) responsible for your country processes this data and results of segmentation at its own responsibility. The national sales company (importer) responsible for your country will contact you using the contact information available via message (email, SMS, in-app, push) and by telephone. You can view the national sales company (importer) responsible for your country at the following link: https://connectgo.volkswagen-we.com/importer/#load/layer/importer.
To tailor advertising to you personally, Volkswagen AG and the national sales company (importer) responsible for your country process data regarding your usage behaviour in the context of advertising delivery (e.g. opening emails and links within emails). Volkswagen AG processes this data to ensure that segmentation is highly relevant. The national sales company (importer) responsible for your country processes this data to ensure content is highly relevant. This is used as a basis to ensure you receive advertising better suited to your needs in future (e.g. if you click on links/advertising in a particular section of an email, you will receive more emails on this topic). You may of course withdraw your consent to advertising (Article 6, paragraph 1, letter a GDPR) with respect to the national sales company (importer) responsible for your country at any time, without giving reasons, with immediate effect for the future, e.g. by sending an email to the email address in the consent declaration, via the withdrawal link contained in the messages or by contacting Volkswagen AG, e.g. by email to info-datenschutz@volkswagen.de, via the contact details stated in the Site notice or in the Volkswagen ID user account. If you withdraw your consent, Volkswagen AG and the national sales company (importer) responsible for your country will no longer process your personal data for advertising purposes. However, said withdrawal does not affect the lawfulness of data processing prior to withdrawal. Volkswagen AG will also no longer process your personal data for advertising purposes if you have not been contacted for advertising purposes for a year. Volkswagen AG deletes your data after three years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations.
VII. Processing for the purposes of advertising from Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG *
*This section only applies to people permanently resident in Germany
If you wish to receive advertising personally tailored to you from Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG, you must consent to the processing of your data for this purpose (Article 6, paragraph 1, letter a GDPR). If you give your consent, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process personal data from the Volkswagen ID user account and associated services. The following data is processed once you have given your consent:
-private contact and identification data (e.g. surname, first name, email address, telephone number)
-personal details (such as preferred partners)
-transaction data (e.g. parking sessions completed)
-vehicle data (e.g. built-in navigation system in stored vehicles)
-vehicle usage data (e.g. logbook, fill levels)
-contract data (e.g. ongoing contracts with associated services)
-IT usage data (e.g. last logins to services, use of functions)
-campaign data (e.g. time and content of recent campaign delivery)
This data is processed for the following purposes:
Surveys and personally tailored advertising such as information, offers, discounts on new and existing products from Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG (e.g. We services, vehicles and vehicle-related products), products from Volkswagen Group Charging GmbH (e.g. the Elli charging card), products from Mobility Trader GmbH (e.g. used vehicles), products from Urban Mobility International GmbH (e.g. WeShare) and products from national subsidiaries of Volkswagen Financial Services AG (e.g. leasing) and information on and invitations to service and loyalty programmes, delivery of customer magazines, customer and product events (e.g. test drives, product launches, product demonstrations), trade fairs and events. Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG will contact you for these purposes using the contact information available via message (email, SMS, in-app, push) and by telephone.
In order to improve their advertising, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG pseudonymise and segment the personal data stored in your Volkswagen ID user account and associated services and share joint responsibility for this. If you have consented to advertising (Article 6, paragraph 1, letter a GDPR), Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG use the results of segmentation and make a direct personal link with the data mentioned above. For more information on the pseudonymisation and segmentation of your data, please see the section ‘Segmentation for the purposes of advertising optimisation’ in the Privacy Policy for the service you are using. You can find services you use and which are linked to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
To tailor advertising to you personally, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process data regarding your usage behaviour in the context of advertising delivery (e.g. opening emails and links within emails). This is used as a basis to ensure you receive advertising better suited to your needs in future (e.g. if you click on links/advertising in a particular section of an email, you will receive more emails on this topic). You may of course withdraw your consent to advertising (Article 6, paragraph 1, letter a GDPR) with respect to Volkswagen AG or Volkswagen Deutschland GmbH & Co. KG at any time, without giving reasons, with immediate effect for the future, e.g. by sending an email to info-datenschutz@volkswagen.de, via the withdrawal link contained in the messages, via the contact details stated in the Site notice or in the Volkswagen ID user account. If you withdraw your consent, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG will no longer process your personal data for advertising purposes. However, said withdrawal does not affect the lawfulness of data processing prior to withdrawal. Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG will also no longer process your personal data for advertising purposes if you have not been contacted for advertising purposes for a year. Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG delete your data after three years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations.
VIII. General information on the analysis of data from Volkswagen ID *
*This section does not apply to people permanently resident in Germany
Volkswagen AG is constantly striving to develop new products and services, improve the products and services it provides and optimise advertising for the purposes of marketing said products and services. Sound evaluation of the use of current products and services (analytics) is required for this purpose. Accordingly, Volkswagen AG processes data from the Volkswagen ID user account and associated services, such as
-pseudonymous identification data (e.g. a randomly generated pseudonymous user ID) -user account data (such as preferred partners) -transaction data (e.g. completed appointment scheduling) -vehicle usage data (e.g. logbook, fill levels) -contract data (e.g. vehicle equipment, ongoing contracts with associated services)
- IT usage data (e.g. last logins to services, use of functions) -location data (e.g. truncated GPS data) The purposes and nature of processing and the legal basis thereof are described in detail below.
1.Analysis for the purposes of developing and improving products
Volkswagen AG processes data from Volkswagen ID user account for the purposes of developing new products and services (by estimating adoption rates for new products, for example) and improving existing ones (such as by evaluating adoption rates for existing products). For stored vehicles, Volkswagen AG processes the vehicle identification number and adds further equipment data for your vehicle to the above data. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only analysed in Volkswagen AG’s analytics systems once this pseudonymisation has taken place. The direct personal link is not restored at any time. The results of the analytics (particularly metrics and figures) are completely anonymous. Processing of pseudonymous data is required as there are interactions between the Volkswagen ID user account and the relevant services. In these circumstances, the use of the pseudonym is absolutely essential in establishing a connection between the data underpinning the analysis from the Volkswagen ID user account and from the associated services.
Your data is processed as described on the basis of the legitimate interest of Volkswagen AG in offering you new and improved products and services (Article 6, paragraph 1, letter f GDPR). Volkswagen AG deletes your pseudonymised data after five years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations. For more information on the pseudonymisation and analysis of your data, please see the section ‘Analysis for the purposes of developing and improving products’ in the Privacy Policy for the service you are using. You can find services you use and which are connected to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
2.Segmentation for the purposes of advertising optimisation
Volkswagen AG processes data from the Volkswagen ID user account for the purposes of advertising optimisation (e.g. evaluating relevance for a campaign). For stored vehicles, Volkswagen AG processes the vehicle identification number and adds further equipment data for your vehicle to the above data. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only segmented in Volkswagen AG’s analytics systems once this pseudonymisation has taken place. Your data is processed as described based on Volkswagen AG’s legitimate interest in providing optimised advertising tailored to the user (Article 6, paragraph 1, letter f GDPR).
Volkswagen AG deletes your pseudonymised data after three years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations.
Volkswagen AG does not use the results to restore a direct personal link if you have not given appropriate consent to advertising (Article 6, paragraph 1, letter a GDPR). For more information on consenting to advertising from Volkswagen AG, please see the passage ‘Processing for the purposes of advertising’. For more information on consenting to advertising from the national sales company (importer) responsible for your country, please see the passage ‘Processing for the purposes of advertising by the national sales company (importer) responsible for your country’. For more information on the pseudonymisation and segmentation of your data, please see the section ‘Segmentation for the purposes of advertising optimisation’ in the Privacy Policy for the service you are using. You can find services you use and which are connected to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
IX General information on the analysis of data from Volkswagen ID *
*This section only applies to people permanently resident in Germany
Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG are constantly striving to develop new products and services, improve the products and services they provide and optimise advertising for the purposes of marketing said products and services. Sound evaluation of the use of current products and services (analytics) is required for this purpose. Accordingly, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process data from the Volkswagen ID user account and associated services with joint responsibility, such as
-pseudonymous identification data (e.g. a randomly generated pseudonymous user ID)
-user account data (such as preferred partners)
-transaction data (e.g. completed appointment scheduling)
-vehicle usage data (e.g. logbook, fill levels)
-contract data (e.g. vehicle equipment, ongoing contracts with associated services)
-IT usage data (e.g. last logins to services, use of functions)
-location data (e.g. truncated GPS data)
The purposes and nature of processing and the legal basis thereof are described in detail below.
1.Analysis for the purposes of developing and improving products
Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process data from the Volkswagen ID user account for the purposes of developing new products and services (by estimating adoption rates for new products, for example) and improving existing ones (such as by evaluating adoption rates for existing products). For stored vehicles, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process the vehicle identification number and add further equipment data for your vehicle to the above data. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only analysed in Volkswagen AG’s analytics systems once this pseudonymisation has taken place. The direct personal link is not restored at any time. The results of the analytics (particularly metrics and figures) are completely anonymous.
Processing of pseudonymous data is required as there are interactions between the Volkswagen ID user account and the relevant services. In these circumstances, the use of the pseudonym is absolutely essential in establishing a connection between the data underpinning the analysis from the Volkswagen ID user account and from the associated services. Your data is processed as described on the basis of the legitimate interest of Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG in offering you new and improved products and services (Article 6, paragraph 1, letter f GDPR). Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG delete your pseudonymised data after five years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations. For more information on the pseudonymisation and analysis of your data, please see the section ‘Analysis for the purposes of developing and improving products’ in the Privacy Policy for the service you are using. You can find services you use and which are connected to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
2.Segmentation for the purposes of advertising optimisation
Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process data from the Volkswagen ID user account for the purposes of advertising optimisation (e.g. evaluating relevance for a campaign). For stored vehicles, Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG process the vehicle identification number and add further equipment data for your vehicle to the above data. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only segmented in Volkswagen AG’s analytics systems once this pseudonymisation has taken place. Your data is processed as described based on Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG’s legitimate interest in providing optimised advertising tailored to the user (Article 6, paragraph 1, letter f GDPR).
Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG delete your pseudonymised data after three years or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations. Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG do not use the results to restore a direct personal link if you have not given appropriate consent to advertising (Article 6, paragraph 1, letter a GDPR). For more information on consenting to advertising from Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG, please see the passage ‘Processing for the purposes of advertising from Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG’.
For more information on the pseudonymisation and segmentation of your data, please see the section ‘Segmentation for the purposes of advertising optimisation’ in the Privacy Policy for the service you are using. You can find services you use and which are connected to the Volkswagen ID user account at any time in the Volkswagen ID portal https://vwid.vwgroup.io under the menu option ‘Connected apps’.
X. Compliance with legal and regulatory requirements
For direct sales and the provision of digital services, we will process your personal data (first name, surname, address, country) for the purposes of preventing fraud and money laundering, for the prevention, combating and investigation of the financing of terrorism and asset endangering crimes as well as to check against European and international anti-terrorism lists. The requirements for Volkswagen AG result in particular from legal obligations (such as the money laundering act or the European embargo and terrorism regulations). Volkswagen AG may have a legitimate interest in the compliance and observance of requirements imposed by public and other competent governmental authorities - inside or outside your country of residence - so as not to expose Volkswagen AG and its representatives to criminal or civil sanctions. The legal basis for the processing of your personal data for the purposes set out above is, in the case of legal obligations, Article 6, paragraph 1, letter c GDPR or, in the case of a legitimate interest, Article 6, paragraph 1, letter f GDPR. For reasons of our legal and taxation obligations to retain data, we generally retain the personal data you provide for seven years after fulfilling the contract, but – if legally required – we will retain your personal data for up to 30 years after collecting the data to comply with our legal obligations.
XI. Recipients of your personal data and transfer to third countries
If you use your Volkswagen ID to log into a service which is not provided by us, but by a third party, this third party will only be transferred the personal data from your Volkswagen ID to whose transfer you consented when you first logged into this service.
We commission service providers to facilitate use of Volkswagen ID and associated services. These service providers are contractually obliged to comply with provisions of data protection law and are not considered third parties as defined by data protection law. Personal data is only passed on to third parties if this is required for contract processing, particularly for providing services. In the context of using Volkswagen ID, your personal data is processed in an Amazon Web Services cloud operated by Amazon Web Services Inc. (‘Amazon’) in the US. It is not possible to rule out Amazon Web Services, Inc. with headquarters in the US, having access to the personal data, so corresponding EU standard contractual clauses (a contractual arrangement approved by the European Commission according personal data the same protection for data processing in non-EU countries as in the EU) have been concluded. Amazon processes your data exclusively on our behalf and in accordance with our instructions as part of a contract data processing agreement. For the purposes of ensuring smooth operation and development, Volkswagen AG also uses CARIAD SE, with headquarters in Germany, as a processor.
Your personal data is processed for the purposes of advertising optimisation and improving products in an Amazon Web Services cloud operated by Amazon Web Services EMEA SARL (‘Amazon’) in the European Union. It is not possible to rule out Amazon Web Services, Inc. with headquarters in the US, having access to the personal data, so corresponding EU standard contractual clauses (a contractual arrangement approved by the European Commission according personal data the same protection for data processing in non-EU countries as in the EU) have been concluded. Amazon processes your data exclusively on our behalf and in accordance with our instructions as part of a contract data processing agreement. For the purposes of ensuring smooth operation and development, Volkswagen AG also uses CARIAD SE, with headquarters in Germany, as a processor.
In the context of the Customer Interaction Centre (Customer Care) and communication, your personal data is processed in a cloud operated by Salesforce.com EMEA Limited (‘Salesforce’) in the European Union. It is not possible to rule out Salesforce.com, Inc. with headquarters in the US, having access to the information, so corresponding EU standard contractual clauses (a contractual arrangement approved by the European commission according personal data the same protection for data processing in non-EU countries as in the EU) have been concluded. The data processed is also protected by BCR (Binding Corporate Rules) of Salesforce. Salesforce processes your data exclusively on our behalf and in accordance with our instructions as part of a contract data processing agreement. For the purposes of ensuring smooth operation and development, Volkswagen AG also uses CARIAD SE, with headquarters in Germany, as a processor.
Personal data is only disclosed to the national sales company (importer) responsible for your country if you consent to the processing of your data for this purpose. In principle, your personal data is only transferred from Volkswagen AG to the national sales company (importer) responsible for your country in encrypted form. If the national sales company (importer) responsible for your country is in a country outside the European Union and the European Economic Area, we transfer your data to what are known as ‘third countries’ under the GDPR. There may therefore be a lower level of protection for your personal data. To protect your data, Volkswagen AG and the national sales company (importer) have concluded EU standard agreements. You can view the national sales company (importer) responsible for your country at the following link: https://connectgo.volkswagen-we.com/importer/#load/layer/importer.
You can view the EU standard contractual clauses used at the following link: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087
XII. Data retention
1.As a rule, we shall only retain your personal data for as long as is reasonably necessary to fulfil the purposes for which we collected it, including the fulfilment of legal, official, fiscal, accounting or reporting requirements. In the event of a complaint, or if we reasonably assume that there is the prospect of a legal dispute with regard to our relationship with you, we may retain your data for a longer period.
- To determine the appropriate retention period for personal data, we take into account the quantity, nature and sensitivity of personal data, the potential risk of harm due to unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we may achieve these purposes by other means, and the applicable statutory, official, fiscal or accounting requirements. 3.Specific information regarding data storage in conjunction with the specific individual purposes of data processing may be found in the relevant sections above.
C. Your rights
You may assert the following rights vis-à-vis Volkswagen AG at any time free of charge. In such circumstances, we must verify your identity and may ask you for more information or clarification to assist us in seeking and providing the personal data required. You can obtain further information about asserting your rights on the website https://datenschutz.volkswagen.de.
Right to information: You are entitled to obtain confirmation as to whether and which personal data concerning you is processed by us, and to find out to which domestic and overseas third parties your personal data has been transferred. In addition, you are entitled to obtain a copy of the personal data that is the object of processing from us.
Right to rectification: You have the right to request that we rectify any of your personal data that is incorrect or incomplete. You may also request that your data is rectified accordingly by third parties to whom we have passed said data.
Right to erasure: You have the right, in the event that the requirements specified in Article 17 GDPR have been met, to request the erasure of your personal data. In accordance with this provision, you may request the erasure of your data, for instance, if it is no longer necessary for the purposes for which it was collected. Furthermore, you may request erasure if we process your data on the basis of your consent and you revoke this consent. You may also request that your data is erased accordingly by third parties to whom we have passed said Right to restriction of processing: You have the right to request the restriction of the processing of your personal data if the requirements specified under Article 18 GDPR have been met. This is the case, for example, if you dispute the accuracy of your data. You may then request that processing is restricted for as long as it takes to examine the accuracy of your data.
Right to object: You are entitled to object to the processing of your personal data in the following circumstances:
-If the data is processed for the purposes of direct marketing, including profiling in conjunction with direct marketing.
-If the processing, including profiling, is based on the following legal grounds:
-is necessary for the performance of a task carried out in the public interest in accordance with Article 6, paragraph 1, letter e GDPR; or
-are necessary for the legitimate interests of the data controller responsible for processing or a third party in accordance with Article 6, paragraph 1, letter f GDPR and if we are not in a position to demonstrate compelling reasons for processing worthy of protection which outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims. In the event of any such objection, we ask that you indicate the grounds for your objection to the data processing.
Right to data portability: Provided that the data processing is based on consent or on the fulfilment of a contract and that it is also carried out using automated processing, you have the right to receive your data in a structured, common and machine-readable format and to forward it to another data controller. You also have the right to have your personal data transmitted directly by us to another data controller, where technically feasible.
Right of revocation: If the data processing is based on your consent, you have the right to revoke your consent at any time free of charge with effect for the future by contacting datenschutz@volkswagen.de,, via the contact details stated in the Site notice, in the Volkswagen ID portal or via other contact methods of which we inform you.
Right to lodge a complaint: You are also entitled to lodge a complaint with a supervisory authority about our processing of your data. You may do this with the data protection authority at your place of residence, for instance. A list of all data protection authorities in the European Union can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
D. Your point of contact
Data protection officer
Our data protection officer is your point of contact for all issues related to data protection, as well as for the exercising of your rights. We shall investigate your issue and respond to you within a month of receipt of the request. We may extend this period by an additional two months if this is necessary in light of the complexity and number of requests. We will inform you of an extension to the cut-off period within a month of receipt of the request, together with reasons for the delay. If you submit your request electronically, you will be informed by electronic means if possible, unless you indicate otherwise. If you are not satisfied with our response, you may assert your right to lodge a complaint with a data supervisory authority in accordance with Section C above.
Please address your enquiries to:
Datenschutzbeauftragter der Volkswagen
AG Berliner Ring 2, 38440 Wolfsburg, Germany
datenschutz@volkswagen.de
Part II
A. Argentina
I. Applicable law
The processing of personal data of Argentine users in connection with the use of Volkswagen ID will be subject to the provisions of Argentine Personal Data Protection Law No. 25,326 and complimentary regulations (" PDPL").
II. Processing of your personal data.
Legal basis: In deviation from the legal bases described in Part I, the legal basis for processing personal data under the law of Argentina is the data subjects' prior, express and informed consent. The consent of the data subjects is given by registering for the Volkswagen ID, after they have expressly confirmed that they have read and accepted the Privacy Policy. Therefore, if You do not agree with this Privacy Policy please leave the Volkswagen ID website and refrain from registering for the Volkswagen ID.
III. Recipients of your personal data and transfer to third countries
If you use your Volkswagen ID to register for a service which is not provided by us but by a third party, we will only transmit personal data from your Volkswagen ID to such third party, if and to the extent you have given prior consent to the transmission during the initial registration for such service. We commission service providers in connection with the processing of your requests and your use of the Volkswagen ID and the associated services. These service providers are contractually obligated to comply with data protection regulations and are not considered third parties under data protection law. We only transmit personal data to third parties to the extent necessary for the performance of the contract, in particular for providing the services.
We only transmit personal data for purposes of advertising and market research if you consent to the processing of your data for this purpose.
The personal data we process in connection with your use of the Volkswagen ID is stored in an Amazon Web Services cloud operated by Amazon Web Services Inc. ("Amazon") in the USA. Access to the personal data by Amazon Web Services, Inc. based in the USA cannot be ruled out, and we have therefore concluded standard contractual clauses (an agreement which gives personal data the same protection it has in Argentina for data processing in foreign countries) accordingly. Amazon processes your personal data exclusively on our behalf and according to our instructions in accordance with a data processing agreement. The processing of your personal data in connection with the Dialogue Center (Customer Service) for the Volkswagen ID and the associated services as well as in connection with advertising communication takes place in a cloud operated by Salesforce.com EMEA Limited ("Salesforce"). Access to the information by Salesforce.com, Inc. based in the USA cannot be ruled out, and we have therefore concluded standard contractual clauses (an agreement which gives personal data the same protection it has in Argentina for data processing in foreign countries) accordingly. Data processed for contractual purposes (such as information regarding changes to our Terms of Use) is also protected by BCR (Binding Corporate Rules) of Salesforce. Salesforce processes your personal data exclusively on our behalf and according to our instructions in accordance with a data processing agreement.
B. Bosnia and Herzegovina
In deviation from the legal bases described in Part I, the legal bases for processing personal data under the law of Bosnia and Herzegovina is a consent given by the data subjects. The consent of the data subjects is given by registering for the Volkswagen ID, after they have confirmed that they have read and accepted the Privacy Policy.
Data controller representative in Bosnia and Herzegovina:
Porsche BH d.o.o. Sarajevo
BIH-71000 Sarajevo | Bulevar Meše Selimovića br 16
C. Brazil
Brazilian General Data Protection Law no. 13.709/18 (LGPD) applies in full extent to any processing operation carried out in the following circumstances, irrespective of the country in which the controller's headquarter is located:
I – the processing operation is carried out in the Brazilian territory;
II – the purpose of the processing activity is the offer or supply of goods or services or the processing of data of individuals located in the Brazilian territory; or
III – the personal data is collected in the Brazilian territory.
Under the LGPD personal data collected in the Brazilian territory is understood as personal data whose data subject is in the Brazilian territory at the time of the collection.
Deviation from Part I on the topic of Recipients of your personal data and transfer to third countries:
Service providers commissioned in connection with the processing of your requests and your use of the Volkswagen ID and the associated services are considered to be third parties under the LGPD. It means that, if a data subject requests information on how its data is processed, the controller is obligated to inform the type of processing and responsibilities of all parties who carry out the processing.
Deviation from Part I on the topic of Data Subjects' Rights:
Right to object – in addition to the general right to object described in Part I of the Privacy Policy, the LGPD provides that data subject has also the right to oppose to processing of his/her data whenever the processing is not in compliance with the provisions of the LGPD and the processing is carried out under any legal basis other than consent.
Right to data portability – under the LGPD right of portability has the following meaning: portability of the data to other service providers or suppliers of product, at the express request, and observing the business and industrial secrets, in accordance with the regulation of the controlling body.
Deviation from Part I on the topic of Data Retention:
The personal data shall be eliminated after termination of the processing thereof, within the scope and technical limits of the activities, and conservation thereof shall be authorized for the following purposes:
I -compliance with a statutory or regulatory obligation by the controller;
II – studies by a research body, guaranteeing, whenever possible, the anonymization of personal data;
III -transfer to third parties, upon compliance with the data processing requirements set forth in this Law; or
IV – exclusive use of the controller, provide the data are anonymized, it being understood that the access thereto by third parties is prohibited.
D. Chile
Como excepción a los fundamentos jurídicos descritos en la parte I, la base jurídica para el tratamiento de los datos personales en virtud de la legislación de Chile es el consentimiento expreso de los interesados. El consentimiento expreso de los interesados se da al registrarse para obtener la Volkswagen ID, después de que hayan confirmado que han leído y aceptado la Política de Privacidad.
Derecho a la supresión de los datos: YTiene derecho a obtener la supresión de sus datos personales si se cumplen las condiciones especificadas en el artículo 17 de la Ley de Protección de Datos Personales, si sus datos personales están obsoletos o anticuados, en caso de que los haya facilitado voluntariamente o si los ha facilitado únicamente con el fin de recibir comunicaciones comerciales y no desea seguir figurando en dicho registro. En consecuencia, podrá obtener la supresión de sus datos, por ejemplo, si ya no son necesarios para los fines para los que fueron recogidos. Además, podrá obtener la supresión si procesamos sus datos sobre la base de su consentimiento y usted retira dicho consentimiento. También puede solicitar que sus datos sean suprimidos en consecuencia por terceros a los que hayamos transferido estos datos.
Derecho a la limitación del tratamiento: Tiene derecho a obtener la limitación del tratamiento de sus datos si se cumplen los requisitos del artículo 18 de la Ley de Protección de Datos, en el caso de que haya facilitado sus datos voluntariamente y si éstos se facilitaron únicamente para comunicaciones comerciales y no desea seguir figurando en dicho registro. Este es el caso, por ejemplo, si usted impugna la exactitud de sus datos. Durante el tiempo que dure la verificación de la exactitud de los datos podrá obtener la limitación del tratamiento.
E. India
Grievance officer: Our grievance officer is available to you for redressal of all concerns and grievances that you may have in relation to this Privacy Policy. Please direct your concerns/grievances to:
Volkswagen grievance officer / Volkswagen data protection officer
AG Berliner Ring 2, 38440 Wolfsburg, Germany
F. Japan
Personal information obtained from residents in Japan ("Personal Data") shall be handled in accordance with the following rules in addition to the rules set forth in Part I of this Privacy Policy.
1. Purpose : We will handle the Personal Data in accordance with the Purposes set forth in Part I of this Privacy Policy ("Purposes"), and not use Personal Data for any purpose other than such Purposes. We shall promptly notify the relevant data subjects, or disclose to the public of the Purposes (and any subsequent changes thereof), unless the Purposes have already been disclosed to the public;
2. Collection : We will not obtain any Personal Data through any deceptive, fraudulent, or other wrongful means;
3. Accuracy : We will make reasonable efforts to ensure that Personal Data handled by us is accurate and up to date and within the scope necessary to achieve the Purposes;
4. Retention : We will retain Personal Data in accordance with Section XI of Part I of this Privacy Policy, and cease retention as soon as it is reasonable to assume that the Purposes are no longer being served by retention of Personal Data;
5. Protection : We will protect Personal Data in its possession or under its control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, damage, loss or similar risks. We will adequately supervise processing of Personal Data by our officers, employees, third party vendors and any other parties who process Personal Data on our behalf;
6. Transfer: Without obtaining the prior consent of the relevant data subjects, we will not transfer or provide any part of Personal Data to any individual or entity unless an exception under the Act on the Protection of Personal Information ("APPI") applies.
7. Extraterritorial Transfer : Without obtaining the prior consent of the relevant data subjects, we will not transfer or provide any part of Personal Data to any individual or entity located outside Japan, European Union or the United Kingdom unless (a) a transferee is located in a country or area certified by the Personal Information Protection Commission of Japan ("PPC") as having data protection standards equivalent to those of Japan or (b) the transferee has data protection standards equivalent to the standards specified by the PPC; and,
8. Data Subject's Right : If a data subject requests pursuant to the APPI disclosure of Purposes, access to, correction, or deletion of any of Personal Data relevant to such data subject, or lodge a complaint, we will respond to such request or complaint promptly and in accordance with the APPI. Any fee charged to data subjects shall be reasonable.
G. México
1. Base jurídica para el tratamiento de datos personales
La base jurídica para el tratamiento de datos personales de los usuarios de la Volkswagen ID con nacionalidad mexicana es, el consentimiento del interesado previo, explícito e informado. Usted da su consentimiento del interesado confirmando expresamente las condiciones de uso y que ha leído la Política de privacidad en el curso del registro.
2. Datos personales sensibles
En el contexto del tratamiento de sus datos personales, se tratan los siguientes datos personales sensibles:
-información de las listas de sanciones nacionales e internacionales
-delitos penales
Le informamos que estos datos personales sensibles solo se tratarán para los siguientes fines:
-cumplimiento de las obligaciones legales derivadas de la Ley contra el lavado de dinero o de la
-norma europea sobre embargo y terrorismo
-identificación del cliente
-creación y gestión de la cuenta de usuario de Volkswagen ID
-uso de la cuenta de usuario de Volkswagen ID para servicios de Volkswagen AG y de terceros
Volkswagen AG tiene acceso a estos actos sancionadores nacionales e internacionales mediante bases de datos públicas, mismas que pueden ser consultadas por los interesados en los siguientes sitios web: https://www.bafin.de/DE/Aufsicht/Geldwaeschepraevention/Laender_und_Sanktionslisten/Laender_und_Sanktionslisten_node.html https://eeas.europa.eu/topics/sanctions-policy/8442/consolidated-list-of-sanctions_en.htm
3. Transmisión de datos personales
Terceros destinatarios | Datos personales transmitidos | Finalidades del uso de los datos personales |
---|---|---|
Amazon Web Services EMEA SARL | - El tratamiento de datos personales en relación con la prestación de servicios de Volkswagen ID - El tratamiento de datos personales para mejorar los productos - El tratamiento de datos personales para mejorar la publicidad | prestación de servicios de Volkswagen ID - Mejora de los productos - Mejora de la publicidad |
Salesforce.com EMEA Limited | - El tratamiento de datos personales para mejorar el Centro de Interacción con el Cliente (atención al cliente) - El tratamiento de datos personales para mejorar la publicidad - publicidad de Atención al cliente | - Atención al cliente - Publicidad |
Cariad SE | - El tratamiento de datos personales en relación con la prestación de servicios de Volkswagen ID - El tratamiento de datos personales para mejorar los productos - El tratamiento de datos personales para mejorar la publicidad - El tratamiento de datos personales para mejorar el Centro de Interacción con el Cliente (atención al cliente) - El tratamiento de datos personales para mejorar la publicidad | -prestación de servicios de Volkswagen ID - Mejora de los productos - Mejora de la publicidad - Atención al cliente - Publicidad |
4. Derechos ARCO
Tiene derecho a saber qué datos personales trata Volkswagen AG, así como para qué fines y bajo qué condiciones Volkswagen AG trata estos datos. Asimismo, usted tiene derecho a solicitar la rectificación o modificación de sus datos personales en caso de que estén desactualizados, sean inexactos o estén incompletos (derecho de rectificación), a la supresión de sus datos personales de nuestros registros y bases de datos si considera que no están siendo tratados conforme a los principios, tareas y obligaciones previstas en la Ley de Protección de Datos de México (derecho de supresión), y a oponerse al tratamiento de sus datos personales para fines específicos (derecho de oposición). Estos derechos se conocen comúnmente como derechos ARCO.
Para ejercer sus derechos ARCO, debe enviar un documento escrito a Volkswagen AG Berliner Ring 2, 38440 Wolfsburg, Alemania o por correo electrónico a Proteccion.DatosPersonales@volkswagen.de con al menos la siguiente información:
-nombre, apellidos e indicación de un canal de comunicación para recibir notificaciones
-copia de su documento oficial de identificación
-información explícita de Volkswagen sobre el derecho ARCO que desea ejercer
-datos personales que son objeto del derecho ARCO ejercido
-cualquier otra información que ayude a Volkswagen a encontrar sus datos personales
Si el derecho ARCO es ejercido por un representante legal, se debe probar la personalidad jurídica de la persona que firma.
Las consultas de los interesados se procesarán y responderán de acuerdo con el artículo 32 de la Ley de Protección de Datos de México. Una vez recibida su solicitud, Volkswagen AG le notificará sobre la aprobación o rechazo dentro de los siguientes 20 días y tomará la decisión en los 15 días siguientes a la notificación de la aprobación. Si su solicitud no cumple con todos los requisitos establecidos en el presente documento (a excepción de los puntos I o II) dentro de los primeros 5 días de la recepción de su solicitud, Volkswagen AG tiene derecho a presentar una solicitud de información para satisfacer todos los requisitos. En este caso, se le dará un plazo de 10 días para cumplir con dicho requerimiento, de lo contrario, su solicitud se considerará como no presentada.
En caso de que no reciba ninguna respuesta o comentario por parte de Volkswagen de acuerdo con el procedimiento previamente establecido, tendrá derecho a presentar una queja en contra de Volkswagen ante la Autoridad Mexicana de Protección de Datos (INAI). Para más información, visite el sitio web www.inai.org.mx. Para más información sobre el proceso del ejercicio de sus derechos ARCO, póngase en contacto con nuestro Departamento de Privacidad a través del correo electrónico [Proteccion.DatosPersonales@volkswagen.de] (mailto:Proteccion.DatosPersonales@volkswagen.de).
H. South Africa
Compulsory to provide your personal data: In order for you to access certain services, it is compulsory for you to provide us with certain personal data. If the provision of personal data is compulsory for receipt or access to a service, then you will not be able to access and/or make full use of the service until you have provided us with the personal data.
The definition of data subjects: In the context of South Africa, a "data subject" refers to any "person" to whom personal data relates. A person, for the purposes of South Africa, means "a natural person or a juristic person". Accordingly, all references to data subject in this Privacy Policy refers to both natural persons and juristic persons, where the data subject is located in South Africa.
Transfer of personal information to third parties located outside of South Africa : We may, from time to time, need to transfer to and/or store your personal data on servers in a jurisdiction other than where it was collected, and we hereby notify you that such jurisdiction may not have comparable data protection legislation.
Your right to lodge a complaint: When the Protection of Personal Information Act, 2013 (" POPIA") becomes of force and effect, you will have a right to lodge a complaint to the Information Regulator (inforeg@justice.gov.za) for any contravention of POPIA.
I. Switzerland
The provisions contained in Part I apply to you as a Swiss customer – being this an individual or a legal entity – without restriction, unless otherwise agreed below on the basis of the Swiss Federal Act on Data Protection (FADP).
1.When Part I speaks of a "legitimate interest", we mean our overriding private interest in processing your data in connection with the conclusion or performance of our services under the Volkswagen ID (Art. 13 para. 2 lit. a FADP).
1.When Part I speaks of your "consent", we mean your explicit and voluntary consent given on the basis of our adequate information (Art. 4 para. 5 FADP).
1.Certain data processing is subject to the EU standard contractual clauses or protected by the EU-US Privacy Shield and BCR (Binding Corporate Rules) of Salesforce, both of which are compliant with Swiss data protection law and do extend through the Swiss-US Privacy Shield also to personal data of subjects with permanent residence in Switzerland.
1.You are entitled to the rights mentioned under Part I, with the following amendments:
-Right to erasure: You have the right to obtain the erasure of incorrect data without having to meet certain conditions (Art. 5 para. 2 FADP); -Right to object: You have the right to object to the processing of your data at any time and without giving reasons (Art. 12 para. 2 lit. b FADP); and
Right to lodge a complaint : You have the right to lodge a complaint with the Federal Data Protection and Information Commissioner about our processing of your data, if the methods of processing are capable of breaching the privacy of larger number of persons (system errors; Art. 29 para. 1 lit. a FADP).
J. Turkey
Right to demand indemnification: You have the right to demand indemnification in case you suffer damages occurring from the unlawful processing of your personal data.
Data controller representative in Turkey:
Hergüner Bilgen Özeke Avukatlık Ortaklığı, Büyükdere Caddesi 199, Levent 34394, İstanbul TÜRKİYE