A. Responsible party
Thank you for visiting a website operated by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, firstname.lastname@example.org, listed in the register of companies of the District Court of Braunschweig under HRB 100484 (Volkswagen AG). In the section below, we would like to inform you about the collection, processing and use of your data.
B. General information
It is possible to visit Volkswagen AG websites without providing us with any information about your identity. In this case, we would only receive the following log data automatically:
- An anonymous Cookie-ID, which does not allow your IP address to be identified
- The operating system and web browser you are using as well as your current screen resolution
- The date and time of your visit
- The pages you visit on our website
- The website from which you came to us
Unless otherwise specified in the following, your data is processed exclusively by Volkswagen AG.
C. Collecting, processing and using your personal data
I. Inquiries to Volkswagen Commercial Vehicles Customized Solution
You can submit queries to Volkswagen Commercial Vehicles Customized Solution via this website, and also via VW systems or using the email accounts provided there.
Your personal data will only be collected, processed and/or used if you send us this, for example for configuring or changing the content of a contractual relationship concluded between you and us [cf. Art. 6(1)(b) GDPR], registration for personalised services [cf. Art. 6(1)(b) GDPR] or an inquiry via our partner contact form in the form of consent [Art. 6(1)(a) GDPR].
The following personal data may be required in order to process your case: surname, first name, address, email address, or the vehicle identification number (VIN).
This information would then be sent to Volkswagen Group Services GmbH where necessary (as data processor for customer service) or the supplier or body builder involved in the respective conversion (see https://www.bb-database.de/jctumbau/en/web/international/unsere-partner).
The data collected will be deleted no later than 30 days following completion of the processing of your case, provided that it is not subject to other retention requirements (e.g. for tax purposes).
II. The newsletter is sent to registered users of the Conversion Portal/Bodybuilder Database and Conversion Managers at the Volkswagen Commercial Vehicles importers.
The Customized Solution business unit at Volkswagen Commercial Vehicles works together with external converters. This collaboration allows employees of these companies to register as users in the Conversion Portal/Bodybuilder Database. These registered users and the Conversion Managers at Volkswagen Commercial Vehicles importers receive newsletters on topics such as:
- Technical Information (e.g. information on WLTP)
- New products
- Updates to bodybuilder guidelines
- News from the Customized Solution business unit (e.g. change of contact persons at Customized Solution, new guidelines for the creation of company profiles and advertisements, new brand and communications guidelines, new logos, new PartnerSystem brochures, new criteria or new incentives for the various partnership levels)
- Invitations to specialist events (e.g. converter evening at the IAA)
- Invitations to training sessions/workshops (e.g. product training sessions, technical expertise, partnership with VW Commercial Vehicles, processes and VW Commercial Vehicles, Conversion Manager qualification)
- Other relevant topics pertaining to the business relationship (e.g. joint appearances at trade fairs)
The newsletter is sent on a monthly basis.
The list of newsletter recipients comprises registered users of the Conversion Portal/Bodybuilder Database and Conversion Managers at Volkswagen Commercial Vehicles importers. Only business contact and organisation data is used for the list of recipients (name, email address, company, partnership status of the company in the Conversion Portal/Bodybuilder Database, industry, title, language, country of the company department).
This personal data is used on the basis of overriding legitimate interest [cf. Art. 6(1)(f) GDPR]. Volkswagen AG is sending the aforementioned information to the registered users of the Conversion Portal/Bodybuilder Database and importers’ employees to ensure that they can plan and implement conversions for their own respective employer that fit the current basic vehicles. For the planning of future conversions, they will also receive information on new products and changes to products such as equipment packages and new or different vehicle configuration options. It is in the interest of Volkswagen AG to send the information to converters who are responsible for these conversions. In this way, Volkswagen AG, converters and importers can ensure that their joint end customer receives a technically sound conversion. With this process described, Volkswagen AG is not acting primarily out of self-interest, but in the interest of converters, importers and their joint end customers.
The newsletter is sent via the Customized Solution resources mailbox.
The newsletter recipients have the option to cancel the newsletter at any time by sending an informal email (opt-out clause).
III. Declaration of consent for advertising and market research
After logging in, registered users are able to sign up to receive additional advertising material and to take part in market research in addition to the newsletter mentioned above. The data provided in this context (email address, surname and first name) will be used exclusively by us for the purpose of providing this service within the scope of your given consent [Art. 6(1)(a) GDPR]. You may withdraw your consent with future effect to Volkswagen AG at any time and free of charge. You can do this directly in your user profile on the Conversion Portal/Bodybuilder Database or via the following website https://datenschutz.volkswagen.de.
To help us improve our business cooperation with the bodybuilders, we conduct anonymous satisfaction surveys. For this purpose we send links to online questionnaires by post (exclusively to company addresses without personal reference) or by email (personal contact to the email address stored in the Conversion Portal/Bodybuilder Database). The personal invitation by email will only be sent if you have given the above-mentioned consent [Art. 6(1)(a) GDPR] in advertising and market research. The questions in the online questionnaires relate solely to the business cooperation between the legal entities involved (Volkswagen AG and the respective bodybuilder); no personal data will be collected from you.
IV. Documenting legal instructions in ElsaPro for the use of informational material regarding conversions
The Customized Solution business unit at Volkswagen Commercial Vehicles of Volkswagen AG works together with external converters. This collaboration allows employees of these companies to register as users in the Conversion Portal/Bodybuilder Database. When entering information for the first time, the employee must confirm that the converter is responsible for the provision and accuracy of the information. In addition, the employee of the converter must confirm in the Guarantee category that the Conversion Portal is not to be used for recalls that relate to a risk to life and limb. Both confirmations are saved in the Conversion Portal with the dealer portal ID of the user and a time stamp. The data processing is based on an overriding legitimate interest of Volkswagen AG [cf. Article 6(1)(f) GDPR].
Employees of the service partners of VW Commercial Vehicles can also register on the Converter Portal via the Converter informational material in ElsaPro. To register, the employee must confirm a legal notice that the information that follows is not provided by Volkswagen AG, but is the responsibility of the respective converter. After providing the dealer portal ID and a time stamp, confirmation of the notice is saved on the Conversion Portal. When the converter’s service information is accessed, the respective service partner employee must confirm that they will adhere to the specifications made by the converter. After providing the dealer portal ID and a time stamp, confirmation of this notice is also saved on the Conversion Portal. Data processing is based on an overriding legitimate interest of Volkswagen AG [cf. Article 6(1)(f) GDPR].
The aforementioned data (dealer portal ID and time stamp) are retained for five years.
Documentation of the aforementioned legal notices supports Volkswagen AG’s interest in ensuring that the responsibilities of the parties involved as pertains to the provision of and adherence to service information that is defined in the Conversion informational material in ElsaPro have been verifiably acknowledged.
V. Calculation of CO2 in converted vehicles
In the logged-in area of this website, registered users are able to calculate vehicle-specific WLTP values. The following personal data is collected: Vehicle identification number (VIN), reference number and commissioning number. The data provided in this context is used by us exclusively for the purpose of providing this service in the context of fulfilling legal obligations in accordance with Regulation (EU) 1151/2017 EG [Art. 6(1)(c) GDPR]. The data collected will be stored for a maximum of 35 years.
D. Your rights
You may exercise the following rights vis-à-vis Volkswagen AG at any time without cost. You can obtain further information about asserting your rights in section E.
Right of access: You are entitled to information from us about how we process your personal data.
Right to rectification: You have the right to obtain from us the rectification of any inaccurate or incomplete personal data concerning yourself.
Right to erasure: You have the right to request the erasure of your data, provided the preconditions stated in Article 17 of the GDPR have been met. For example, you may obtain erasure of your data if they are no longer necessary for the purposes for which they were collected. You may also obtain erasure if we process your data based on your consent and you withdraw that consent.
Right to restriction of processing: You have the right to demand restriction of the processing of your data if the conditions set out in Article 18 of the GDPR are met. That is the case, for example, if you dispute the accuracy of your data. You can then demand a restriction of the processing for the period it takes to verify the accuracy of the data.
Right to object: You have the right to object to your data being processed if processing is based on an overriding interest or your data are used for the purposes of direct marketing. An objection is permitted if processing is conducted in either the public interest or for the exercise of official authority or if it is conducted for a legitimate interest of Volkswagen AG or of a third party. If you object to the processing of your data, please notify us of the grounds for your objection. You also have the right to object to data processing for the purposes of direct marketing. The same applies to profiling, insofar as it is related to direct marketing.
Right of data transferability: You have the right to receive your data in a structured, commonly used and machine-readable format and to transfer this data to another data processor, provided that data processing is based on consent or contract fulfilment and that automated processing methods are used.
Right of withdrawal: Provided data processing is based on your consent, you have the right to withdraw that consent to the processing of your personal data free of charge at any time, and with effect for the future.
Right to lodge a complaint: You also have the right to lodge a complaint about the processing of your data with a supervisory authority (such as the Data Protection Commissioner for the Federal State of Lower Saxony [Landesbeauftragte für den Datenschutz Niedersachsen]).
E. Your contact persons
Contact persons for exercising your rights
The contact persons for exercising your rights and further information can be found on the following website https://datenschutz.volkswagen.de.
Data protection officer
If you have any data protection concerns, please contact our data protection officer:
Volkswagen AG Data Protection Officer
Berliner Ring 2, 38440 Wolfsburg, Germany
Version dated April 2020