By following this link, you are leaving the Volkswagen AG Website. Volkswagen AG does not adopt websites of third parties that can be reached by links and is in no way responsible for their content. Volkswagen has no influence over what data is being collected, saved and processed by third parties. Further information on this subject can be found in the data privacy statement of the responsible party of the external website.
We are pleased that you are visiting a website of Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, registered in the Commercial Register of the Amtsgericht Braunschweig (Braunschweig District Court) under No. HRB 100484 ("Volkswagen AG"). This document explains how we collect, process, and use your data.
B. General Information, Protocol Data
You are in general able to visit the websites of Volkswagen AG without telling us who you are. In this case we will only receive the following protocol data:
- the operating system and browser that you are using and your screen resolution setting and
- the date and time of your visit.
Insofar as the following sections do not contain opposing information, the data processing shall be undertaken exclusively by Volkswagen AG.
C. Collection, Processing, and Use of Your Personal Data
I. Use of the Web Form for Information Requests
On this website you can request information about your personal data processed by Volkswagen AG in accordance with Article 15 GDPR via web form. The data provided in this context (surname, forename, date of birth, address and optionally Volkswagen ID or e-mail address, vehicle identification number, beginning and end of ownership as well as corresponding ownership documentation) shall be used by us exclusively for the purposes of providing information, identification and legitimisation subject to your information request (Art. 6 Para. 1 Clause 1 lit. c GDPR). For confirmation of your request and e-mail address, Volkswagen AG uses the so-called double opt-in procedure. In this procedure, you will receive an email to the provided e-mail address asking you to confirm. We document the following data in connection with the double opt-in procedure:
- IP address, date and time of sending the web form
- IP address, date and time of confirmation of double opt-in email
You may withdraw your information request vis-à-vis Volkswagen AG, using the e-mail address: email@example.com at any time.
When using the web form, an encrypted connection is created between your end device and our server. Our security measures correspond to the state-of-the-art standards and are continuously improved based upon the technological developments.
II. Processed data
In the following, it is discussed in detail for what purpose the input fields on the web form are required:
Name: Your full name shall be used for the collection of the personal data processed within Volkswagen AG. Moreover, your name shall also be used for the identification of your person and, as required, for the legitimisation of your vehicle ownership(s).
Birthdate: Your birthdate shall be used only for the identification of your person and the collection your personal data processed within Volkswagen AG. Surname, forename and date of birth in combination ensures a correct identification as these information are available on all international identification cards. That is how we make sure that personal data are not forwarded to unauthorised third parties. Thus, we can ensure that no personal data is disclosed to unauthorized third parties.
Address: Your address (with the obligatory data: Street, house number, postal code, city, country) shall be used for the collection of the personal data processed within the Volkswagen AG. Moreover, we shall require your address (with the aforementioned obligatory data) for the identification of your person and, as required, for the legitimisation of your vehicle ownership(s). Additionally your address is needed in order to send you the information report via post.
Volkswagen ID / e-mail address: If you would like to receive information about the personal data stored in the central Volkswagen ID user account including the linked digital services, we shall require the e-mail address which you provided as an Volkswagen ID. If you should have no central Volkswagen ID user account, you may provide your e-mail address. Your Volkswagen ID and/or e-mail address shall be used for the collection of the data processed within the Volkswagen AG and for the double opt-in procedure and for communication with you, e.g. for queries regarding your request.
If you want to provide multiple Volkswagen ID / e-mail addresses, please submit an additional information request.
Vehicle identification number: If you would like to likewise receive information regarding your personal data associated with a Vehicle Identification Number (VIN), we shall require that you provide the corresponding vehicle identification numbers and in addition, the timeframe (beginning and end of ownership) for which you are entitled to receive information. In order to verify whether you are entitled to receive information, we shall require that you provide vehicle ownership documentation and/or a consent/permission from the respective vehicle owner (legitimisation). On the corresponding documents which provide proof of the vehicle ownership, any data which are not required should be redacted by you, see Information Sheet on the Redaction of Unrequired Data on Verification Documents.
III. Legitimation in case of vehicle usage by third parties
In order to grant you personal data concerning the provided vehicle, which you are not the owner of, the consent/permission of the respective vehicle owner for the time of granting is required.
Therefore, we use the declaration of consent (Article 6 Para. 1 lit. a GDPR, Article 6 Para. 1 lit. c GDPR), which is deposited from the vehicle owner at datenschutz.volkswagen.de to clearly associate the personal data from the vehicle to their corresponding person. In the context of obtaining the consent, the following data from the vehicle owner are collected for the purpose of legitimation or contact establishment due to the processing of your request: name, forename, address of the vehicle owner, vehicle identification number (VIN) as well as a telephone number or an e-mail address optionally.
In order to associate the vehicle to the associated owner the following data are collected from the requesting person: name, birthday and the usage duration of the vehicle.
IV. Retention Timeframe for Your Issue
Protocols of the communication with you will be retained by Volkswagen AG for one calendar year including the personal data you transmitted to Volkswagen AG. The documented communication also contains, among other things, the information report which you receive from Volkswagen AG. The processing is based on a balance of interests in accordance with Art. 6 (1) lit. f GDPR. Volkswagen AG represents the following interests: During the retention period, the documentation of your issue will enable the Volkswagen AG to review queries and complaints which you submit and will also enable the Volkswagen AG to process your issue quicker. If you already passed the identification and legitimisation process the results can thus be re-used for exercising additional rights, avoiding you to have to repeat your identification and legitimisation.
V. Use of data processing companies
In order to fulfil legal obligations as well as to make use of our own justified interests we engage data processing companies. Your data provided is just processed within European Economic Area (EEA).
The following data processing companies are engaged to work on your request:
- Volkswagen Group Services GmbH
- Salesforce.com EMEA Limited
For the support of our IT system the following order processor is used:
- Reply AG
VI. Processing of Additional Data During the Identification Process via the POSTIDENT Procedure
Insofar as we cannot clearly identify you in the Volkswagen AG’s systems, additional identification measures shall be required in order to ensure that no personal data are disclosed to unauthorised third parties. For this, Volkswagen AG shall use the POSTIDENT procedure of the Deutsche Post AG, which enables you to make identification via video-chat or at a post office branch within 4 weeks after our notification. After completing the procedure, the Deutsche Post AG will send us your identification data, which we shall use exclusively for verifying your identity. After successful identification has been made, we shall erase your personal data that have been processed during the POSTIDENT procedure. Information on how our identity provider, Deutsche Post AG, processes personal data is accessible on: https://www.deutschepost.de/en/p/postident/postid.html
D. Your Rights
You may assert your rights below against Volkswagen AG at any time upon a free-of-charge basis. For further information concerning the exercise of your rights, please see section E.
Right to Information: You shall have the right to receive information from us regarding the processing of your personal data.
Right to Correction: You shall have the right to demand that we correct your personal data, which are incorrect and/or incomplete.
Right to Erasure: You shall have the right, in the event that the requirements specified in Art. 17 GDPR have been met, to demand the erasure of your data. Thus, in accordance with this Art. 17, for example, you may demand the erasure of your data insofar as these data are no longer required for the purposes for which they were collected. Furthermore, you may demand the deletion of these data if we process your data based upon the consent, which you have granted, and you then withdraw this consent.
Right to Restrict the Processing: You shall have the right to demand the restriction of the processing of your data if the requirements specified in Art. 18 GDPR have been fulfilled. This is, for example, the case if you dispute the correctness of your data. For the duration of the verification of the correctness of the data, you may demand the restriction of the processing.
Right to Object: Insofar as the processing is undertaken based upon an overriding interest or your data are used for the purposes of direct advertising, you shall have the right to object to the processing of your data. An objection shall be permissible (sic!) if the processing either is carried out in the public interest or in the exercising of official authority or owing to a justified interest of Volkswagen AG or of a third party. In the event that you object, we request that you state your reasons to us regarding why you are objecting to the data processing. In addition, you shall have the right to object to the data processing for the purposes of direct advertising. This shall also be valid for profiling insofar as this is undertaken in conjunction with the direct advertising.
Right to Data Transferability: Insofar as the data processing is undertaken based upon a consent or a fulfilment of a contractual agreement and this is also undertaken while using an automated processing system, you shall have the right to receive your data in a structured, commonplace and machine-readable format and to transfer these data to another data processing service provider.
Right of Revocation: Insofar as the data processing is undertaken based upon a consent, you shall have the right to withdraw your consent for the data processing, with effectiveness for the future, at any time and upon a free-of-charge basis.
Right to Complain: You shall also have the right to complain to a government supervisory authority (e.g. to the State Data Protection Officer for Lower Saxony, Germany) regarding our processing of your data.
E. Your Contact Persons
Contact Person for Exercise of Your Rights
For further information concerning the exercise of your rights, please see datenschutz.volkswagen.de.
Data Protection Officer
Our Data Protection Officer shall support you as your contact person on all data protection-related matters:
Data Protection Officer of Volkswagen AG
Berliner Ring 2, 38440 Wolfsburg
Status: March 2019