VIN Specification for provider of telematics devices - 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, SKODA, SEAT AND CUPRA BRANDS (VIN SPECIFICATION FOR PROVIDER OF TELEMATICS DEVICE)

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 an external software provider for the configuration of a telematics device ordered by you 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 makes certain VIN-related vehicle master data technically available to an external software provider for the configuration of a telematics device ordered by you, so that this telematics device can be technically configured for you at a car dealer/workshop or importer selected by you. The data is provided to this external software provider for the purpose of fulfilling your contract for an agreed online connectivity service, including the necessary prior product test.  

D. Data categories

Volkswagen Group Info Services AG receives the following personal data from Volkswagen AG (Berliner Ring 2, 38440 Wolfsburg), 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 external software provider:   

1. VIN; 

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

3. Contract number/documentation for your contract with your chosen car dealer/repair shop/importer to ensure that only VIN-based Volkswagen vehicle master data with a valid contract is provided by Volkswagen Group Info Services.

E. Legal basis  

The legal basis for processing of personal data within the product framework through Volkswagen Group Info Services AG are:

The necessary fulfillment of the contract concluded by you (Art. 6 para. 1 lit. b GDPR) including the agreed online connectivity services. 

 The legitimate interest of Volkswagen Group Info Services AG (Art. 6 para. 1 lit. f GDPR). 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 in centrally providing the data transmitted by the brands of the Volkswagen Group to Volkswagen Group Info Services AG to an external software provider via our data hub (https://drivesomethinggreater.com/) so that car dealers/workshops/importers can successfully configure these online connectivity services with this external software provider. 

F. Data recipients  

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

  • the contracted software provider (e.g. Connected Cars A/S, Park Allé 355, 2605 Brøndby, Denmark); 

  • the car dealer with whom you concluded the contract for the acquisition of the telematics device;

  • the importer from whom the car dealer ordered the telematics device;

  • if applicable, processors of the above-mentioned data recipients; and

  • processors of Volkswagen Group Info Services AG.   

G. Data source  

We receive your data from:

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

  • 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.  

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 external software provider. 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 provider of telematics device' (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 lodge a complain with 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 May 2024