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Data protection

A. Responsible party


We are pleased that you are visiting a website of Volkswagen AG Berliner Ring 2, D-38440 Wolfsburg, Germany, vw@volkswagen.de, registered in the Commercial Register No.:100484 Registration Court: Amtsgericht Braunschweig ("Volkswagen AG"). In the following we inform you how your personal data is processed by Volkswagen AG in relation to your visit to the website.

B. Processing of Your Personal Data


I. Processing of Log Files

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:
  1. the operating system you are using, the web browser you are using, and the screen resolution setting you are using,
  2. the date and time of your visit,
  3. the web sites of ours that you have visited,
  4. the web site from which you are visiting us.
  5. To activate certain functionalities, the country of origin is determined on the basis of your IP and is stored temporarily if necessary
  6. An anonymous cookie ID

Insofar as the following sections do not contain opposing information, the data processing shall be undertaken exclusively by Volkswagen AG.
This data is processed in accordance with Article 6 Paragraph 1 lit. f General Data Protection Regulation (GDPR) based on our legitimate interest to be able to display the website to you properly. The data is deleted after 90 days.

We use the data processor Arvato - Bertelsmann SE & Co. KGaA for the hosting of this website. The appropriate data processing contract is in place.

II. Registration and Purchase of Maintenance and Repair Information

After you register on erWin, you will find specific vehicle and model-based information (e.g. workshop manuals, current flow diagrams). In order to call up specific vehicle information it is obligatory to enter a vehicle identification number (VIN).

For model-based information it is not necessary to input a vehicle identification number (VIN). You will receive a selection list for the specific model using which vehicle models and associated documents can be found.

You also receive access to ODIS on erWin. ODIS helps you with the diagnosis of vehicles using the necessary software and data.

For registration, orders and invoicing on the site we process the necessary personal data, such as you name, your address, your telephone number, your e-mail address, your username and your password.

Your bank details are not saved at Volkswagen AG when a purchase is made. Instead they are transferred directly via an interface to the system of your main bank which acts on its own authority.

If you are a contractual partner yourself, we process your date in the interest of contractual obligation as per Art. 6 Para. 1 lit. b) GDPR. If you are not a contractual partner yourself, but are rather acting on behalf of your company, we process your data based on legitimate interest as per Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the provision of the service to your client.

In order to be able to make all the required maintenance and repair information available to you, the vehicle identification number (VIN) is processed as per Art. 6 Para.1 lit. c GDPR in conjunction with EURO5/6 legislation (EU Regulation 692/2008, EU Regulation 715/2007, EU Regulation 566).

Personal data is only collected, processed and/or used if you provide us with it voluntarily, for example to process your order or to register for the use of the repair and maintenance information or if you send us an inquiry via the website. If it is necessary to pass the data on to third parties, for example to collect the purchase price per credit card, your data will be transmitted to these third parties.

In the "My erWin” section, you can change your user account via the link "Change registration" or deregister it. i.e. the personal reference/user account is completely cancelled. If you do not use erWin for a period of two years, your entire registered data will be deleted. This applies even if you have already made use of our service. In order to counteract misuse of data by third parties, the data is transmitted in encrypted form. Your data will be processed within the Federal Republic of Germany.

It is impossible to rule out the possibility that your data will be processed by other Volkswagen companies (Audi AG, SEAT S.A., Skoda a.s., Bentley Motors Ltd., Automobil Lamborghini S.p.A., MAN SE) in individual cases within the scope of collaboration within the business group. The data is of course deleted immediately once they are no longer required for the achievement of the purpose. When processing data Volkswagen AG draws upon legitimate interest as per Art. 6 Para.1 lit. f) GDPR in order to be able to process your enquiries adequately.

III. Contact Form

In case of technical problems or for general enquiries you have the option of contacting us using a contact form and sending us an enquiry. In relation to this we process the following data:
mandatory: E-mail address and optionally: operating system, browser.

We process the personal data you specify there in order to contact you and process your enquiry (cf. Art. 6 Para. 1 lit. b GDPR). Arvato - Bertelsmann SE & Co. KGaA and Volkswagen Vertriebsbetreuungsgesellschaft mbH IS-Handel Deutschland provide us with support as data processors when processing.

We delete your data as soon as we have answered your enquiry unless other statutory retention periods apply (e.g. retention periods for tax purposes).

C. Use of Cookies and Tracking Tools


Volkswagen AG uses various cookies on its websites. Cookies are small files containing configuration information that are stored on your end device. There are basically three categories of cookies. There are cookies which are essential for the functionality of the website (so-called functional cookies), cookies which increase the user-friendliness of a website visit and, for instance, save your language settings (so-called comfort cookies) and cookies which are used to create a pseudonymised user profile (so-called tracking cookies).

The processing of the Functional Cookies is necessary to enable your visit to the website (cf. Art. 6 Para. 1 lit. GDPR).

The legal basis for convenience cookies is legitimate interest (Art. 6 Para. 1 lit. f GDPR). The legitimate interest is providing comfort when visiting the website. You can object to data processing at any time with effect for the future by preventing the storage of cookies by making the appropriate setting in your browser.

Tracking Cookies are only set if the website visitor has given their consent (Art. 6 Para. 1 lit. a GDPR). Consent is given via the so-called cookie banner, which must be actively clicked on. We currently do not use any tracking cookies.

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 F.
Right to information: You shall have the right to receive information (Art. 15 GDPR) from us regarding the processing of your personal data.
Right of rectification: You can independently change your personal or incorrect personal data in the User Portal at any time.
Right to delete: You have the right to demand the deletion of your data if the conditions set out in Art. 17 DSGVO exist. Accordingly, you can for example request 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 information based on your consent and you revoke this consent.
Right to restriction of processing: You have the right to demand the restriction of the processing of your data if the conditions of Art. 18 GDPR exist. This is the case, if you challenge the correctness of your data for example. For the duration of the verification of the correctness of the data you can then demand the restriction of processing.
Right to object: Insofar as the processing is undertaken based upon an overriding legitimate interest, you shall have the right to object to the processing of your data.  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 of data portability: If data processing is based on consent or contract fulfilment and this is done using automated processing, you have the right to receive your data in a structured, established and machine-readable format and to communicate it to another data processor.
Right of revocation:  If the data processing is based on a consent, you have  the right to revoke the consent, with effectiveness for the future, at any time and upon a free-of-charge basis.
Right of appeal: You shall also have the right to lodge a complaint to a government supervisory authority (e.g. to the The Data Protection Commissioner for the state of Lower Saxony) regarding our processing of your data.

E. Your Contact Persons

Contact Person for Exercise of Your Rights

The contact persons for the assertion of your rights and for further information can be found at the following website https://datenschutz.volkswagen.de.

Data Protection Officer

​Our Data Protection Officer shall support you as your contact person on all data protection-related matters:

Datenschutzbeauftragter der Volkswagen AG (Data Protection Officer of Volkswagen AG)
Berliner Ring 2, D-38440 Wolfsburg, Germany
datenschutz@volkswagen.de

Issue: December 2020

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