I. Processing of log files
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When you visit our website, we process the following log files from you, which do not allow any inference to your person:
- An anonymous cookie ID which does not make it possible to infer your IP address,
- the web browser you are using,
- the date and time of day of your visit,
- the websites which you have visited on our website and
- the website from which you are visiting our website.
The legal basis for processing this personal data is Article 6 paragraph 1 letter b GDPR (processing for the performance of a contract or prior to entering into a contract), and its purpose is a proper display of the website. We delete this log data automatically on behalf of a deletion routine after 42 days.
II. Processing of user account data
There is a need for specific user data to be stored in the process of registration which is defined by the requirements mandatory for the first local administrator and further authorized users. Each user account in the Dealer-Portal belongs to one OrgID. Only employees of the following departments can be defined as users:
- Retailer (incl. garages and independent market participants)
- Importer
- Distribution Center
- Agency
- Department
- Region
- OE dealer (original equipment dealer)
For the registration process, the following data is required:
- Title
- First name
- Surname
- Password
- Language
In addition to these, which are mandatory for all users, the first local administrator of an Org ID has to specify the last three digits of an ID card, the birthday and the work email-address. For access to some of the downstream applications, further fields may need data. An email address is mandatory for authorisation assignment of local user administration rights in the Dealer-Portal.
In the Dealer-Portal, local admins and users themselves are able to store contact data, such as telephone extension, fax machine number, mobile phone number, email address and title, e.g. to ensure swift accessibility to one user’s contact data to clarify possible account issues.
Moreover, local admins may fill in the following data, for reasons of one’s possible user account evaluation made easier:
- Department
- Area
- Vendor ID
The Dealer-Portal is globally accessible, including third countries. Users can access their own data visible in their browsers. (Admins may additionally check upon data of other users.)
The legal basis for processing this personal data is our legitimate interest of being able to provide the website properly and offer a platform with safe user access to downstream applications that are essential for your work. (Article 6 paragraph 1 letter f GDPR).
III. Deletion of your personal data
By deactivation of your Dealer-Portal account, the access to the functions of the Dealer-Portal itself and all downstream applications are deprived. Your account and all related personal data will be removed by your local admin following the deactivation of your profile (retirement or role authorization withdrawal) within a Year.
In addition, as part of data cleansing processes, the personal data of inactive users on the Dealer Portal will be deleted. The legal basis for processing this personal data our legitimate interest in keeping the database of the Dealer Portal updated. (Article 6 paragraph 1 letter f GDPR).
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IV. Transfer of contact details of Dealer Portal administrators
For users with administrative rights in the Dealer Portal (administrators), it also applies that their stored contact details (first name, last name, work e-mail address) can, if necessary, be transferred to administrators at higher sales levels (e.g. to wholesalers, OEM/brand companies, Volkswagen AG) within the Volkswagen sales network for the purpose of rolling out new versions or functions of the Dealer Portal. This transfer or processing of personal data is based on our legitimate interest in being able to provide and further develop the Dealer Portal properly (Article 6 paragraph 1 letter f DSGVO). In the case of administrators who are employees of Volkswagen AG, this forwarding or processing is carried out in accordance with § 26 paragraph 1 BDSG for the purpose of carrying out the employment relationship.
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V. Commissioning of data processors
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The data processing of Volkswagen AG mentioned in this privacy policy are carried out exclusively by Volkswagen AG or by service providers commissioned by Volkswagen AG. The necessary data protection agreements have been concluded with these service providers.