VIN Specification for fleet - privacy policy

PRIVACY POLICY FOR THE PROVISION OF VIN-RELATED VEHICLE MASTER DATA BY VOLKSWAGEN GROUP INFO SERVICES AG FOR THE VOLKSWAGEN PASSENGER VEHICLES, VOLKSWAGEN COMMERCIAL VEHICLES, AUDI, SKODA, SEAT AND CUPRA BRANDS (VIN SPECIFICATION FOR FLEET)

This privacy policy informs you about the processing of your personal data by Volkswagen Group Info Services AG.    

Volkswagen Group Info Services AG is the central interface to mobility data of several brands of the Volkswagen Group. The provision of VIN-related vehicle master data to a specific fleet operator as the current owner/holder of the vehicle, or fleet management software provider on behalf of a fleet operator is carried out centrally by us.

A. Controller according to GDPR

The entity responsible for processing your personal data is Volkswagen Group Info Services AG. You can contact us at the following address:   

Volkswagen Group Info Services AG  

Berliner Ring 2  

38440 Wolfsburg  

Germany   

volkswagen.group.data.business@cariad.technology   

Commercial register number HRB 207876 (Braunschweig Local Court)  

Website: https://drivesomethinggreater.com/

B. Data Protection Officer  

Our data protection officer is available to you as a contact for all data protection-related concerns. Please direct your inquiries to:  

Data Protection Officer of Volkswagen Group Info Services AG  

Berliner Ring 2  

38440 Wolfsburg   

Germany  

privacy@cariad.technology

C. Purpose of the data processing  

Volkswagen Group Info Services AG provides certain VIN-related vehicle master data on vehicles of the Volkswagen Passenger Cars, Volkswagen Commercial Vehicles, Audi, Skoda, Seat, and CUPRA brands to the specific fleet operator who is currently the owner/holder of this vehicle, or to a fleet management software provider on behalf of the fleet operator. This data is provided for the purpose of fleet management as well as the associated process improvement and increase in efficiency in fleet operations, including the necessary prior product testing. 

Volkswagen Group Info Services AG receives the VIN-related vehicle master data from the brands of the Volkswagen Group and then makes this data technically available as a central interface to mobility data of several brands of the Volkswagen Group to the specific fleet operator who is the current owner/holder of this vehicle, or fleet management software provider on behalf of such a fleet operator as owner/holder of this vehicle.

D. Data categories

Volkswagen Group Info Services AG receives the following personal data from Volkswagen AG (Berliner Ring 2, 38440 Wolfsburg), Audi AG (Auto-Union-Str. 1, 85057 Ingolstadt), ŠKODA AUTO a.s. (tř. Václava Klementa 869, 293 01, Mladá Boleslav) and SEAT CUPRA, S. A. U. (Autovía A-2, km 585, 08760 Martorell) and forwards them to the fleet operator as the current owner/holder of a specific vehicle, or fleet software provider on behalf of a fleet operator as owner/holder of this vehicle:   

1. VIN;  

2. vehicle master data (e.g., model year, model number, transmission type, fuel type, etc.);

3. Name and address in the case of individual entrepreneur (as fleet operator) or in the event that the company name under commercial law (Section 17 HGB) or the specific company identifier is also personal data within the meaning of the GDPR (e.g. name of the entrepreneur is also his or her company name), and

4. contract number/documentation for fleet operator´s contract with its chosen fleet software provider to ensure that only VIN-based Volkswagen vehicle master data with a valid contract is provided by Volkswagen Group Info Service.

E. Legal basis  

The processing of personal data by Volkswagen Group Info Services AG is based on the legitimate interest pursuant to Art. 6 para. 1 lit. f DSGVO. Volkswagen Group Info Services AG is the central interface for the provision of mobility data of several brands of the Volkswagen Group and has the legitimate interest to process the data transmitted by the Volkswagen Group brands to Volkswagen Group Info Services AG for the provision of VIN-related vehicle master data to authorized fleet operators, or fleet software provider on behalf of a fleet operator for the purpose of a more efficient management of fleet vehicles and to provide these data centrally via our Data Hub (https://drivesomethinggreater.com/).

In the case of a contractual relationship with fleet operator as an individual entrepreneur, the legal basis is the necessity for the fulfillment of the contract concluded with you (Art. 6 para. 1 lit. b GDPR).

F. Data recipients  

Your data will be provided to the following data recipients for the purpose defined above:    

  • fleet operator in possession/holding of the respective vehicle (data controller);  

  • data processor on behalf of the respective fleet operator (e.g. fleet software provider); and

  • data processors of Volkswagen Group Info Services AG).

Further recipients or categories of recipients of personal data of Volkswagen Group Info Services AG are regularly listed with an updated privacy policy. 

G. Data source  

We receive your data from:

  • Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany,    

  • AUDI AG, Auto-Union-Str. 1, 85057 Ingolstadt,   

  • ŠKODA AUTO a.s., tř. Václava Klementa 869, 293 01, Mladá Boleslav, 

  • SEAT CUPRA, S.A.U., Autovía A-2, km 585, 08760 Martorell.  

H. Storage period  

Generally, your personal data will not be stored by Volkswagen Group Info Services AG. The Volkswagen Group Info Services AG makes your data technically available as a central interface to mobility data of several brands of the Volkswagen Group from the respective brand to the specific fleet operator as the current owner/holder of the vehicle, or fleet software provider on behalf of a fleet operator. Therefore, the data is merely transferred through, without being stored by us.    

For commercial accounting (German HGB), tax compliance (German AO) and data protection accountability (Art. 5 para. 2 GDPR) reasons, Volkswagen Group Info Services AG only archives in a revision-proof manner that data of the product 'VIN Specification for fleet operators  (see point D.) was provided to a specific recipient for a specific VIN on the basis of a specific contract (contract number/documentation), without storing the specific transferred data as content itself.

I. Your rights  

You may assert your rights against Volkswagen Group Info Services AG at any time and free of charge.  

Further information on exercising your rights can be found on the website https://privacy.drivesomethinggreater.com  

Right of access

You have the right to access, i.e., to request confirmation from us as to whether and - if so - which personal data concerning you are being processed and to whom such data has been disclosed as a data recipient. In addition, you generally have the right to receive a copy of your personal data processed by us. We would like to point out that Volkswagen Group Info Services AG, as the central interface to mobility data of several brands of the Volkswagen Group, only transmits the data technically but does not store the transmitted data itself (see point H.).  

Right to rectification  

You have the right to demand that we correct any personal data relating to you that is incorrect or incomplete. We would like to point out that Volkswagen Group Info Services AG, as the central interface to mobility data of several brands of the Volkswagen Group, only transmits the data but does not store the transmitted data itself (see point H.).  

Right of erasure

You have the right to demand the deletion of your data if the conditions set out in Art. 17 GDPR apply. According to this, you can, for example, demand the deletion of your data if it is no longer necessary for the purposes for which it was collected. You can also request deletion if we process your data on the basis of your consent and you revoke this consent. We would like to point out that Volkswagen Group Info Services AG, as the central interface to mobility data of several brands of the Volkswagen Group, only transmits the data but does not store the transmitted data itself (see point H.).  

Right to restriction of processing  

You have the right to request the restriction of the processing of your data if the conditions of Art. 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. You can then request the restriction of processing for the duration of the verification of the accuracy of the personal data. We would like to point out that Volkswagen Group Info Services AG, as the central interface to mobility data of several Volkswagen Group brands, only transmits the data but does not store the transmitted data itself (point H.).  

Right to data portability  

If the data processing is based on consent or the performance of a contract, and if it also involves the use of automated processing, you have the right to obtain your data in a structured, common and machine-readable format and to have it transferred to another controller. In addition, you have the right to have the personal data transferred directly from us to another controller. We would like to point out that Volkswagen Group Info Services AG, as the central interface to mobility data of several brands of the Volkswagen Group, only transmits the data but does not store the transmitted data itself (see point H.).  

Right of objection  

If we process your data on the basis of legitimate interests, you have the right to object to the processing of your data at any time on grounds relating to your particular situation. If your objection relates to data processing for direct marketing purposes, you have a general right to object, which we will implement without giving reasons.    

Right of withdrawal  

If data processing is based on consent, you have the right to revoke your consent at any time free of charge with effect for the future by sending an email to volkswagen.group.data.business@cariad.technology

Notice in accordance with Art. 11 GDPR 

We would like to point out that in many cases we, as Volkswagen Group Info Services AG, are not able to identify the additional vehicle users of a vehicle or the main vehicle users and that we are not obliged under Art. 11 GDPR to obtain or process additional information in order to identify data subjects.   

If you assert rights against us, we must verify your status as a data subject according to GDPR and may ask you for further information if necessary. This also serves to ensure that we may not violate the rights of third parties when releasing personal data, according to GDPR data subject rights.  

Automated individual decisions  

There is no automated decision-making according to Art. 22 GDPR.  

Right of appeal 

You also have the right to complain to a supervisory authority about the processing of your data by us. The competent supervisory authority for Volkswagen Group Info Services AG is:   

The State Commissioner for Data Protection of Lower Saxony,   

Prinzenstraße 5,   

30159 Hannover,    

poststelle@lf.niedersachsen.de   

  

Status October 2024