Privacy Policy

a. Processing of log files

When you visit our website, we process the following log files relating to you; these files contain no personally identifiable information and hence cannot be traced back to you:

• An anonymous cookie ID, which does not allow your IP address to be identified
  
• The operating system and web browser you are using, and your selected screen resolution
  
• The date and time of your visit
  
• The pages you visit on our website
  
• The website from which you came to us
  
• The IP address of the device with which you are accessing the website.
  

For the hosting of this website, we use the processor Amazon Web Services (Amazon Web Services, Inc.) and the Google Cloud Platform (Google Ireland Ltd.). In addition, Adobe (Adobe Systems Software Ireland Ltd.) and Lighthouse (LIGHTHOUSE SARL) as providers for Content Delivery Networks (CDN), a network of connected servers for the delivery of media content, act as data processors. Since access to the data from an insecure third country cannot be ruled out, so-called EU standard contracts have been concluded as an appropriate guarantee for data processing in non-European countries.

The processing of this data is carried out in accordance with Article 6 (1) lit. f DSGVO due to our legitimate interest in being able to properly display the website to you. The data will be deleted after 30 days. In order to be able to offer 3D streaming on our website, we process your IP address.

3D streaming is used to display vehicle models in a virtual, three-dimensional environment, which you can operate interactively.

We use ZeroLight Limited (Live Works, 55-57 Quayside, Newcastle, UK NE1 3DE) as a processor for the 3D streaming. ZeroLight Limited supports Volkswagen AG by providing cloud-based 3D vehicle visualisation.

This data is processed in accordance with Article 6 (1) (f) DSGVO on the basis of our legitimate interest in being able to properly display the 3D streaming to you and to ensure technical monitoring. The personal data is automatically deleted after 30 days at the latest.

The following offers of the Volkswagen Driving Experience (a-d) and the associated data processing are provided under joint responsibility together with D&T DRIVE & TRAINING AG, Ehreshoven 23, 51766 Engelskirchen entered in the Commercial Register of the Local Court of Cologne under No. HRB 87441. Volkswagen AG and D&T DRIVE & TRAINING AG have entered into agreements within the meaning of Art. 26 DSGVO with regard to their joint responsibility. We will inform you of the essential contents of these agreements upon request. For this purpose, please use the contact options listed in the section "Your contact persons". Volkswagen AG is responsible for safeguarding the rights of the data subjects; further information can be found in the sections "E. Your rights" and "F. Your contact persons".

a.  Contact request to the Volkswagen Driving Experience

You have the option of contacting us by telephone or by e-mail. In this context, we process the following data: mandatory: telephone number or e-mail address and optional: title. We process the personal data you provide when contacting us in order to process your enquiry (cf. Art. 6 Para. 1 lit. b DSGVO). The data you provide will be deleted at the latest two weeks after we have answered your enquiry. Your enquiry will be answered by D&T DRIVE & TRAINING AG.

b.  Ordering a Volkswagen Driving Experience voucher

By ordering a voucher, you intend to enter into a contractual relationship with the Volkswagen Driving Experience. Your enquiry constitutes an initiation of a contract (Art. 6, Para. 1 Sentence lit b, DSGVO). We collect the following data, first name, surname, title, street, house number, postcode, city, e-mail and birthday. Your data is required in the course of the business relationship and is used by us for the correct execution, e.g. voucher dispatch. The personal data processed in the course of the voucher order will be deleted 3 years after the voucher has been redeemed, provided that there are no other retention periods (e.g. tax retention periods of 6 years for invoices). The voucher order is processed by D&T DRIVE & TRAINING AG.

c. Training and Tours of the Volkswagen Driving Experience

With a training and/or tour enquiry you intend to enter into a contractual relationship with Volkswagen Driving Experience. Your enquiry constitutes an initiation of a contract (Art. 6, Para. 1 Sentence lit b, DSGVO). We collect the following data, first name, last name, title, e-mail. Your data is required in the course of the business relationship and is used by us for the correct execution, e.g. for sending information material and reservation confirmation. If no contract is concluded, your personal data will be deleted two weeks after the enquiry, personal data that accrues during the fulfilment of a contract will be deleted after 3 years, invoices will be kept for 6 years due to tax retention periods. The processing of the booking is carried out by D&T DRIVE & TRAINING AG.

d. Subscription to Volkswagen Driving Experience newsletter

By sending an e-mail to info@driving-experience.eu you have the option of ordering a newsletter. The e-mail address provided in this context will be used by us exclusively for the purpose of providing this service within the framework of your consent given for this purpose (Art. 6 Para. 1 lit. a DSGVO). D&T DRIVE & TRAINING AG uses the so-called double opt-in procedure for this purpose. In this process, an e-mail is sent to the e-mail address you have provided with a request to confirm your consent. You can revoke your consent at any time free of charge with effect for the future to Volkswagen AG, e.g. via the "Unsubscribe" link contained in every newsletter or via an e-mail to info@driving-experience.eu with the request to unsubscribe. You can find more information on exercising your rights in the "Your rights" section of this data protection declaration.

As soon as you unsubscribe from the newsletter, your personal data provided for the newsletter will be deleted, unless other retention periods (e.g. tax retention periods) apply. The newsletter is sent by D&T DRIVE & TRAINING AG.

a. General information

The Volkswagen AG uses various cookies on its websites. Cookies are small files with configuration information that are stored on your end device. Cookies can basically be divided into three categories. There are cookies which are indispensable for the functionality of the website (so-called function cookies), cookies which increase the comfort of a website visit and, for example, save your language settings (so-called comfort cookies) and cookies on the basis of which a pseudonymised usage profile is created (so-called tracking cookies).

The processing of the comfort cookies is necessary to enable you to visit the website (cf. Art. 6 para. 1 lit. b DSGVO). The legal basis for the convenience cookies is a legitimate interest (Art. 6 para. 1 lit. f DSGVO). The legitimate interest lies in the provision of convenience when visiting the website.

Tracking cookies are only set if the website visitor has consented to this (Art. 6 para. 1 lit. a DSGVO). Consent is given via the so-called cookie banner, which must be actively clicked on.

You can object to data processing at any time with effect for the future by preventing the storage of cookies through the setting in your browser or by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager:
Manage My Cookie Preferences

For more information about our cookies, please see our Cookie Policy and the following.

• Smart Signals
  Based on the usage analysis described above, Smart Signals controls the display of personalised content on Volkswagen's websites. No personal data is collected or processed in this process.
• Ensighten
  Ensighten is a tag management tool and controls the tag integrations described here. Ensighten itself does not collect any personal data for this purpose.

b. Adobe Analytics

This website uses the web analysis service Adobe Analytics to evaluate user access to this website. The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO).

For the evaluation, cookies are stored on your terminal device and information is collected about it, which is also stored on servers of our order processor Adobe Systems Software Ireland Limited ("Adobe"). Access to the information by Adobe Systems Incorporated based in the USA cannot be ruled out, so that corresponding EU standard data protection clauses have been concluded as appropriate guarantees for data processing in non-European countries. You have the right to be informed about this standard contract in the context of the information.

A direct personal reference of the information stored on the Adobe servers is excluded, as 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 the IP address is anonymised before this so-called geolocation by replacing the last octet of the IP address with zeros. The approximate location of the user is added to the tracking packet that still contains the full IP address for statistical analysis. Before the tracking packet is stored, the IP address is then replaced by a single fixed IP address - this is called a generic IP address - if the setting "Obfuscate IP -Removed" is configured. This means that the IP address is no longer included in a stored data set.

In order to optimise common content and functions, Volkswagen AG passes on anonymous analysis results of user behaviour to selected group companies such as the Volkswagen Financial Services AG.

c. Adform

This website uses the web tracking tool Adform. Adform is a demand side platform and is used as a tool for programmatic buying of digital advertising space. Adform uses cookies to serve ads that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Adform uses a cookie ID to record which ads are shown in which browser and can thus prevent them from being shown more than once. Adform also uses this cookie to understand the content you have interacted with on our websites so that we can later send you targeted advertising. In addition, Adform can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees an Adform ad and later visits the advertiser's website with the same browser and makes a purchase there. The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent at any time with effect for the future by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager: https://www.volkswagen.de/de/mehr/rechtliches/datenschutz.html?open=true

The basis of data processing is user data. The IP address, website URL, URL of a previously visited page, marketer domain, Adform cookie ID, user agent, timestamp and referrer are processed. Access to collected data is restricted to Volkswagen AG, Adform A/S and phd Germany GmbH. The duration of data storage is 13 months.

Further information on Adform can be found at https://site.adform.com and on data protection at Adform A/S Denmark in general: https://site.adform.com/privacy-center/overview.

d. The Trade Desk

This website uses The Trade Desk ("TTD" for short), a so-called targeted advertising service. The company provides a technology that helps advertisers manage digital advertising campaigns across many channels such as websites, or apps. The advertising campaigns run by Volkswagen AG help to pay for the content you like. TTD collects and uses data as a processor to ensure that the ads you see on the internet are relevant and to measure and evaluate their effectiveness.

The platform collects and processes pseudonymised - i.e. not directly identifying - data about users, devices and ads, and where they are shown. TTD acts as a sub-processor for the company PHD Germany GmbH. PHD Germany GmbH is an order processor of Volkswagen AG. Corresponding contracts for order processing have been concluded.

The processed data include: Cookie ID, mobile device ID, IP address, interest information, web browser and device information, information about which advertisements have already been displayed to you, timestamp and website URLs.

In doing so, the cookie data used helps to distinguish and recognise web browsers and devices in order to better target our advertising to you and your interests. The TDID (the cookie set by TTD) has a lifetime of 1 year from the last time you received an ad from the platform (TTD). This lifetime can be updated every time you interact with the platform. This will cause the year to start again. The cookie collects technical web browser profile data and the user's browsing behaviour (e.g. data about users, devices and ads, as well as their placement) (see above). All data is stored exclusively in pseudonymised form. In order to be able to transfer requests for ads and other data about users or devices between sellers and buyers and to be able to show you ads that correspond to your probable interests, TTD carries out cookie synchronisation, i.e. the TTD cookie IDs are matched with the cookie IDs of TTD's customers and partners. TTD uses further sub-processors, if necessary and on a case-by-case basis, and makes your data available to third parties for the fulfilment of the order. The standard contractual clauses for the transfer of personal data to processors in third countries apply to the transfer of personal data to recipients who receive the data for the purpose of commissioned data processing. These have been agreed with the sub-processors.

These standard contractual clauses will remain in force until the European Commission decides otherwise, even after the entry into force of the GDPR on 25.05.2018.

https://eur-lex.europa.eu/legal-content/de/TXT/?uri=CELEX%3A32021D0914

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent at any time with future effect by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager: Adjust preferences

In addition, you have the option of directly removing the data already stored in the cookie via the cookie page adsrvr.org of TTD and thus no longer receive personalised advertising via the platform. In this case, the so-called opt-out setting means that you will no longer be shown targeted advertising across TTD customers / partners. Further information on The Trade Desk can be found here: https://www.thetradedesk.com/, as well as on data protection at The Trade Desk, https://www.thetradedesk.com/general/privacy.

e. Sizmek

We also use the Sizmek technology of the provider Sizmek Inc. (401 Park Avenue S, 10016 New York City / USA), which enables us to present you with relevant and targeted advertising material and advertisements, also on third-party offers, on the basis of your interests and your usage behaviour on our offer. We also use Sizmek to measure and statistically evaluate the success of our advertisements (e.g. interaction with or click on an advertisement).

For this purpose, cookies and similar technologies (e.g. pixels and statistical device identifiers) are used on the (end) device with which you visit our website(s) to analyse and evaluate your usage behaviour (e.g. clicks) and interaction with advertisements. The cookies and other technologies do not store any personal data, so you are not personally identifiable to us at any time. The data collected includes non-personal usage-related data (e.g. clicks on advertisements, websites, time and duration of stay) and non-personal browser data (e.g. language setting, screen resolution), which do not allow any inference to your person.

The platform collects and processes pseudonymised - i.e. not directly identifying - data about users, devices and ads, Sizmek acts as a sub-processor for the company PHD Germany GmbH. PHD Germany GmbH is an order processor for Volkswagen AG. Corresponding contracts for order processing have been concluded.

The processed data include: Cookie ID, mobile device ID, IP address, interest information, web browser and device information, information about which advertisements have already been displayed to you, timestamp and website URLs.

The cookie data used helps to distinguish and recognise web browsers and devices in order to better target our advertising to you and your interests (see above).

A direct personal reference of the information stored on the Sizmek servers is excluded, as Sizmek 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 the IP address is anonymised before this so-called geolocation by replacing the last octet of the IP address with zeros. The approximate location of the user is added to the tracking packet that still contains the full IP address for statistical analysis. Before the tracking packet is stored, the IP address is then replaced by a single fixed IP address - this is called a generic IP address - if the setting "Obfuscate IP -Removed" is configured. This means that the IP address is no longer included in a stored data record.

All data is stored exclusively in pseudonymised form.

For the purpose of commissioned data processing, the standard contractual clauses for the transfer of personal data to processors in third countries apply. These have been agreed with the sub-processors.

These standard contractual clauses shall remain in force until the European Commission decides otherwise, even after the entry into force of the GDPR on 25 May 2018.

https://eur-lex.europa.eu/legal-content/de/TXT/?uri=CELEX%3A32021D0914

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent at any time with future effect by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager: Customise preferences

You can object to the use of Sizmek across the board at any time via the Opt-Out Tool at http:/www.sizmek.com/privacy-policy/optedout/ and thus delete all data held about you by our service provider. To do this, simply follow the instructions described there, depending on whether you are visiting our website(s) via a mobile device (e.g. mobile phone, tablet) or another device (e.g. PC). You can find more information on data protection and your settings options in this regard at http:/www.sizmek.com/privacy-policy/optedout.

f. Sophus3

This website uses the web analysis service Sophus3 to evaluate user access to this website. The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO).

For the evaluation, cookies are stored on your terminal device and information is collected via this, which is also stored on servers of our order processor Sophus3 Limited Cyprus ("Sophus3"). The cookies contain session IDs and visitor IDs.

In web analytics, page views and actions (e.g. clicks) on the website are recorded sequentially, i.e. one after the other. The resulting data sets are isolated. A unique session ID, which is stored together with the page views and actions, makes it possible to subsequently assign page views and actions to the common session. A unique user ID allows this to be done across different website visits. The data is used to analyse user behaviour on the website.

A direct personal reference of the information stored on the Sophus3 servers is excluded. A random number is assigned as the visitor ID. The IP address is made unrecognisable (hashed) and shortened (the last two octets are removed). A digital fingerprint (DF) is created. However, it uses the shortened IP address. The DF is itself a hash value and thus a reference back is excluded.

Geolocation does not take place. No geodata is collected.

The data is deleted after 12 months.

You can revoke your consent at any time with future effect by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager: https://www.volkswagen.de/de/mehr/rechtliches/datenschutz.html?open=true.

If you have not consented to the use of tracking mechanisms for the purpose of "Analytics & Personalisation" via our Cookies Banner or Cookie Consent Manager, the analysis service will not be activated. In this case, no data collection will take place.

g. Traci-Script

The Traci-Webscript, is a small program developed by Volkswagen, which has no direct interfaces to third parties. It is used to add or continue dynamic parameters on the Volkswagen.de website (https://www.volkswagen.de/de.html).

The Traci-Web Script can add information to a defined Uniform Resource Locators (URL) as a user moves around the website.

This is a simple text enhancement function. The function takes URL information without personal data, strings them together based on the click path and passes on this URL supplemented by the text.

When the user leaves the Volkswagen website and goes to the Volkswagen Financial Services website (https://www.vwfs.de/), the dynamically added URL parameters are transferred to the Volkswagen Financial Services website, provided the user accepts the cookie policy / data protection declaration when calling up the Volkswagen Financial Services website.  No data is processed.

Right of rectification

You have the right to request the correction (Art. 16 DSGVO) of inaccurate or incomplete personal data that concerns you.

Right of deletion

You have the right to demand the deletion of your data if the conditions set out in Art. 17 DSGVO are fulfilled. 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 demand deletion if we process your data on the basis of your consent and you revoke this consent.

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 DSGVO apply. This is for example the case 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 data.

Right to data portability

If the data processing is based on consent or the performance of a contract and is also carried out using automated processing, you have the right to receive your data in a structured, common and machine-readable format and to transfer it to another data processor.

Right of objection

If the processing is based on an overriding legitimate interest, you have the right to object to the processing of your data. An objection is permissible if the processing is either in the public interest or based on a legitimate interest of Volkswagen AG or a third party. In the event of an objection, we ask you to inform us of your reasons for objecting to the data processing.
You also have the right to object to data processing for direct marketing purposes. This also applies to Profiling, insofar as it is related to direct advertising.

Right of revocation

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.

Right of complaint

You also have the right to complain about our processing of your data to a supervisory authority (e.g. the State Commissioner for Data Protection of Lower Saxony).

The contact details for exercising your rights, along with further information, can be found on the following website: https://datenschutz.volkswagen.de.

Data protection officer
If you have any data protection concerns, contact our data protection officer:

Data Protection Officer, Volkswagen AG
Berliner Ring 2, 38440 Wolfsburg, Germany
datenschutz@volkswagen.de

Version: August 2021