Data Protection Declaration VW DataLab web site
A. Controller
We are pleased that you are visiting a web site of Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, , registered in the Commercial Register of the Municipal Court of Bonn under No. HRB100848 (Commercial Register, Section B) (“Volkswagen AG”). In the following, we should like to inform you on the collection, processing and usage of your data.
B. General Information
In principle, you can visit the web sites of Volkswagen AG without disclosing to us who you are. We will in this case receive only the following protocol data in automated fashion:
1. An anonymous cookie ID which does not make it possible to infer your IP address,
2. The operating system you are using, the web browser you are using and the screen resolution settings which you are using,
3. The date and time of day of your visit,
4. The web sites which you have visited of us and
5. The web site from which you are visiting our web site..
Insofar as the following sections contain nothing to the contrary, the data processing is undertaken exclusively by Volkswagen AG.
C. Collection, Processing and Usage of Your Personal Data
I. Subscribing to Publications and a Newsletter
You shall have the option on this web site of subscribing to publications such as, for example, the business report of Volkswagen AG. In this regard, the following personal data shall be required from you: surname, first name and address. These data shall be used by Volkswagen AG (while deploying a data processor) only for the purposes of the substantiation, content-related formulation or amendment of the contractual agreement concluded between you and us upon a free-of-charge basis in order to subscribe to publications (Art. 6 Para. 1, Sentence 1 lit. b of the General Data Protection Regulation, GDPR). The collected data shall be deleted after the requested publication has been sent insofar as no other retention timeframes (e.g. tax-related retention timeframes) oppose this.
This web site also offers the option of subscribing to a newsletter. The data provided in this context (e-mail address and optionally surname, forename) shall be used by us exclusively for the purpose of rendering this service based upon the consent which you have granted (Art. 6 Para. 1 Clause 1 lit. a GDPR). You may, at any time and upon a free-of-charge basis, withdraw your consent – with effectiveness for the future – vis-à-vis Volkswagen AG, e.g. by clicking on the “Cancel” link which is contained in every newsletter or by using the e-mail address provided below: Insofar as you cancel the newsletter, your personal data shall be deleted insofar as no other retention timeframes (e.g. tax-related retention timeframes) oppose this. The sending of the newsletter shall be undertaken by deploying a contracted data processing service provider to do so.
II. Test Drive
Insofar as you have an interest in one of our vehicles, you can make a request for a test drive via the web site. For this purpose, Volkswagen AG shall collect the following personal data and transmit them to the service partner whom you have selected: XXXXXX. This collection and transmission of the data shall be undertaken by the selected service provider upon the basis of a contract initiation relationship (Art. 6 Para. 1 Sentence 1 lit. b GDPR) regarding the performance of test drives. The transmitted data shall be used by the service partner in order to contact you via your preferred service channel. The data which you provide shall be deleted by Volkswagen AG after being transmitted to the service partner. The service partner shall delete the data after the end of the test drive insofar as no other retention timeframes (e.g. tax-related retention timeframes) oppose this.
III. Declaration of Consent for Advertising and Market Researchin
If you would like to continue to receive information about our products, you can subscribe to this advertising. If you grant your consent in this regard (Art. 6 Para. 1, Sentence 1, lit. a GDPR), the following data shall be processed for the purposes of sending the advertising: surname, forename, e-mail address and/or telephone number. For the obtaining of the consent, Volkswagen AG shall use the so-called double-opt-in process. In this regard, you will be sent an e-mail to your designated e-mail address with the request to confirm that you have granted your consent. Please review the section on “Your Rights” in order to find out how to withdraw your consent.
IV. Requirements-Based Advertising (Targeting)
For the purposes of requirements-based advertising (targeting), Volkswagen AG shall create pseudonymised user profiles (in accordance with Section 15 (3) of the German Telemedia Act (Telemediengesetz). Thus, online campaigns can be controlled in a targeted manner. Pseudonymisation is the replacement of the name and other identification characteristics by a sign for the purpose of preventing the identification of the affected party by third parties or at minimum making it substantially more difficult to make such an identification. In this regard, cookies shall be used. Cookies are small files with configuration information which are saved on your end device. In this regard, information shall be collected regarding your activities on the web sites which you visit (e.g. surfing behaviour, sub-pages visited on the Internet sites which you access, advertising banners clicked, etc.). Most web browsers are set up so that all cookies are automatically accepted. You may, at any time with effectiveness for the future, object to the creation of a pseudonymised user profile by adjusting the settings on your browser in such a manner that it accepts no or only certain cookies or you are notified as soon as cookies are sent. Please note that if you do this, you may not be able to use the full functionality of our web sites. Please see our Cookie Policy for more information on cookies.
D. Tracking Tools
I. Adobe Analytics
This web site uses the web analysis service called Adobe Analytics in order to evaluate the users’ visits to this web site. The data processing shall be undertaken for the purposes of advertising, market research or the requirements-based designing of our web site (in accordance with Section 15 Para. 3 of the German Telemedia Act (Telemediengesetz). For purposes of this evaluation, cookies are stored on your end device and used to collect corresponding information that is also stored on the servers of Adobe Systems Software Ireland Limited (“Adobe”). Access to the information by Adobe Systems Incorporated domiciled in the USA cannot be excluded, so that a corresponding EU standard agreement (adequate guarantees regarding data processing in non-EU countries) was concluded. You shall have the right to be informed of this standard agreement in the course of the disclosure.
You may reject the collection and processing of data at any time with future effect by changing your browser setting to prevent the storage of cookies or by clicking on the “Opt Out” button at http://www.adobe.com/en/privacy/opt-out.html. Please note that your rejection involves setting an opt-out cookie and is therefore only effective if your browser is configured to permit the use of cookies. If you delete this cookie, use a different browser, or switch to a different device, you will have to repeat the process for opting out of Adobe Analytics. Please be informed that in case you delete all of your cookies, this will delete the aforementioned cookie as well, so that it must then be re-installed. Please see our Cookie Policy for more information on cookies.
It is not possible to attribute the information stored on Adobe’s servers directly to individual persons because Adobe Analytics is used with the settings “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed”. The setting “Before Geo-Lookup: Replace visitor’s last IP octet with 0” ensures that, before this so-called geo-localisation, the IP address is anonymised by replacing the last octet of the IP address with zeros. For statistical analysis, the user’s approximate location is added to the tracking package, which still contains the complete IP address. Before saving the tracking package, the IP address shall be replaced by a single fixed IP address – in this regard, one speaks of a generic IP address – if the “Obfuscate IP –Removed” setting has been configured. Thus, the IP address is no longer contained in a saved data set.
II. Google Analytics
This web site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The data processing shall be undertaken for the purposes of advertising, market research or the requirements-based designing of our web site (in accordance with Section 15 Para. 3 of the German Telemedia Act (Telemediengesetz).
Google Analytics uses so-called “cookies”, which are text files placed on your computer, to help the web site analyse how you use the site. The information generated by the cookie about your use of the web site will usually be transmitted to and stored on a Google server in the United States.
In this case, Volkswagen AG shall use the privacy shield negotiated between the European Union and the USA for the ensuring of an appropriate data protection level.
In case of activation of the IP anonymisation on this web site, Google will, however, truncate your IP address beforehand within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. On behalf of the web site provider Google will use this information for the purpose of evaluating your use of the web site, compiling reports on web site activity and providing other services relating to web site activity and internet usage to the web site provider.
The IP address provided by your browser as part of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this web site. In addition, you can prevent Google from collecting and processing the data (including your IP address) generated by the cookie and relating to your use of the web site, as well as the processing of this data by Google, by downloading and installing the browser plug-in available under the following link http://tools.google.com/dlpage/gaoptout?hl=de.
This web site uses Google Analytics with the add-on “_anonymizeIP()”. By so doing, IP addresses are further processed in shortened fashion and it is thus impossible to make a direct attribution to individual persons. Google Analytics is used in compliance with the requirements agreed between the German data privacy authorities and Google.
Information on the third party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001. Data privacy statement: http://www.google.de/intl/de/policies/privacy
III. Piwik
This web site uses the web analytics service Piwik in order to evaluate the users‘ visits to this web site. The data processing shall be undertaken for the purposes of advertising, market research or the requirements-based designing of our web site (in accordance with Section 15 Para. 3 of the German Telemedia Act (Telemediengesetz). For purposes of this evaluation, cookies are stored on your end device. Volkswagen AG will store the data thus collected only on its own servers. If you choose to prevent the storage of cookies, please note that you may not be able to use this web site to its full extent. You may also reject the collection and processing of data at any time with future effect by changing your browser setting to prevent the storage of cookies or by clicking on the “Opt Out-Plug-in” button at: https://datalab-munich.com/cookie-policy/. This web site uses Piwik with the extension “AnonymizeIP”. This abbreviates IP addresses before processing, thus excluding the possibility of any direct personal identification.
E. Social Media
Volkswagen AG uses so-called social media plug-ins (“Plug-Ins”) from the Facebook, Google+ and Twitter social networks which are labelled with the well-known symbols of the respective social network. The Plug-Ins have been deactivated on the web pages of Volkswagen AG as the default setting so that, during the accessing of a web page, no personal data shall be initially passed on to the providers of the Plug-Ins. Only by clicking on one of the greyed-out symbols and by once again confirming a message shall you activate the plug-in which corresponds to a consent in accordance with Art. 6 Para. 1 p. 1 lit. a of the General Data Protection Regulation (DSGVO). After activation has been done, the content from the Plug-In shall be transmitted by the social network directly to your browser and integrated by your browser into the web site (so-called 2-click solution). The plug-ins can be at any time deactivated again by clicking on them anew.
By integrating a plug-in, data are transmitted to the respective provider in automated fashion and can be saved by this respective provider. The provider receives the notification that you have visited our web site. This is done regardless of whether you have set up a user account on the respective social network and are logged-in there or not. If you have logged in to the social network, the provider can classify these data directly to your user account. The possibility exists that the respective providers of the plug-ins will use the data for the creation of usage profiles. Volkswagen AG has no influence on the data collected by the provider and the continued processing thereof. The purpose and scope of the data collection as well as the continued processing and use of the data by the providers of the plug-ins as well as your related rights and setting options in order to protect your private sphere can be found in the respective provider’s Data Protection Declarations.
Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA http://de-de.facebook.com/privacy/explanation.php
Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA https://www.google.de/intl/de/policies/privacy/
Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA https://twitter.com/privacy
F. Your Rights
You may assert your rights below against Volkswagen AG at any time upon a free-of-charge basis:
Right of Access by the Data Subject: You shall have the right to receive information from us regarding the processing of your personal data.
Right to Rectification: 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 of the GDPR have been met, to demand the deletion of your data. Thus, in accordance with this Article 17, for example, you may demand the deletion 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 Restriction of Processing: You shall have the right to demand the restriction of the processing of your data if the requirements specified in Art. 18 of the 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 Portability: 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, by using the following address: or by using the contact data provided in the Imprint section.
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.
G. Your Contact Person: Data Protection Officer
Our Data Protection Officer shall support you as your contact person on all data protection-related matters as well as for the exercising of your rights. Please send your inquiries to the Data Protection Officer of Volkswagen AG.
Data Protection Officer of Volkswagen AG
Berliner Ring 2, 38440 Wolfsburg
status: April 2018
