Volkswagen EV Check App
Privacy Policy

A. Introduction

Thank you for using the Volkswagen EV Check App provided by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, vw@volkswagen.de, entered in the Commercial Register at the District Court of Braunschweig under HRB 100484 (“Volkswagen AG”). We are the controller of the personal data processed through the app for the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"). In the following, we will provide information relating to the processing of your personal data by Volkswagen AG when you use the Volkswagen EV Check app. The latest version of the document can be found in the legal section of this app. We may change this Data Protection Statement from time to time. We will alert you on the app when changes are made.

B. Processing of your personal data

I. Generally no personal data is collected or in any other way processed by Volkswagen AG for the use of the app. Information about the possible processing of personal data, in the context of user behaviour analysis, can be found in the section B.II. Use of tracking tools.

II. Use of tracking tools

1. General information
   
   Volkswagen AG are using tracking tools in order to analyse user behaviour in order to continuously optimize its services based on the needs of the users.
   In this app, tracking for user analysis is only carried out with the consent of the app user (Art. 6 Para. 1 a GDPR).
   The consent is given on the so-called consent screen, which must be actively clicked on.
   The user can revoke the acceptance of tracking user analytics at any time in the settings of this app.
   Cookies are not used in the Volkswagen EV Check app.
    
2. Adobe Analytics
   
   The Volkswagen EV Check App uses tracking tools to offer its functionalities and also to continuously improve user experience.  Data is processed on the basis of the consent provided by you (point (a) of Article 6(1), GDPR).
   
   To undertake this evaluation, relevant information is collected using tags in the app, and transferred to our commissioned data processor Adobe Systems Software Island Limited (“Adobe”), and stored on Adobe servers. Access to the information by Adobe Systems, based in the USA, cannot be ruled out, with the result that corresponding standard EU data protection clauses have been put in place as appropriate guarantees relating to data processing in non-European countries. As part of access/information, you have a right to be notified of this standard contract.
   
   You may withdraw your consent to the data processing at any time with future effect by preventing the use of tracking tools for user analysis in the settings of this app.
   
   It is not possible to link the information stored on the Adobe servers directly to a specific person, since Adobe Analytics is used with the “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed” settings selected. The “Before Geo-Lookup: Replace visitor’s last IP octet with 0” setting ensures that the IP address is anonymised before this geolocalisation by replacing the final octet of the IP address with zeroes. For the purposes of statistical evaluation, the user’s approximate location is added to the tracking package, which still contains the full IP address. Before the tracking package is saved, the IP address is then replaced with an individual, fixed IP address – referred to as a generic IP address – if the “Obfuscate IP-Removed” setting has been configured. This means that the IP address is no longer contained in a data set that is saved.
    
3. Adjust
   
   Volkswagen EV Check app uses the analytics tool „adjust“ in terms of an user optimized creation of this app but also to improve the efficiency of  marketing activities. Data processing is based on your consent (Art. 6 Abs. 1 lit. a GDPR).
   
   Adjust offers a software for mobile apps, which enables the app publisher to measure the success of all marketing and user acquisition activities for the app.
   
   The technology used by adjust is build around the device ID. A Device ID is a string of numbers and letters that identifies every individual smartphone or tablet in the world. On iOS, a device ID is called the ‘Identity For Advertisers’ (IDFA, or IFA for short). On Android, the device ID is the GPS ADID (or Google Play Services ID for Android). adjust uses these device IDs to generate its own unique ID and combines these two for GDPR and privacy-compliant tracking, making it impossible to personally identify a mobile users based on the device or adjust ID or the combination of both.

You may withdraw your consent to represented data processing at any time with effect for the future by preventing tracking tools in the relevant setting within the app.

III. Transmission of geodata

The use of various services (e.g. relating to the calculation of driving behaviour) within the app requires the transmission of geodata, and such transmission is also an elementary component of using the app. Geodata is understood to mean the location data for the mobile device. Geodata will only be transmitted if you have activated this function in the app. You will be asked to approve activation the first time you use the app, and you may withdraw approval at any time by changing the relevant settings. When the app is closed, it uses your background location and physical activity recognition to automatically detect when you’re driving. That way, it can simulate the energy consumption of an EV. 

IV.  Receipt of messages (push notifications)

For some areas, the app offers push notifications (push technology or server push describes a type of communication in which data is provided even when the receiving app is running in the background) to keep you informed, for example reminders to get more information about the models on Volkswagen website. You can configure this function using the menu settings on your end device, and activate/deactivate notifications. For messages to be delivered, it is necessary for us to store a push token for your mobile end device.

C. Your rights

You may exercise the following rights with respect to Volkswagen AG at any time, at no charge. Further information on asserting your rights is provided in the section "How to contact us". Some of these rights are qualified and do not apply in certain circumstances

1. Right of access/information: You are entitled to information (Article 15 GDPR) from us relating to the processing of your personal data.
2. Right to rectification: You have the right to request that we rectify (Article 16 GDPR) any inaccurate or incomplete personal data concerning yourself.
3. 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 ask for your data to be deleted if they are no longer necessary for the purposes for which they were collected. You may also ask for your data to be deleted if we process your data based on your consent and you withdraw that consent.
4. Right to restriction of processing: If any of the prerequisites specified in Article 18 of the GDPR are met, you have the right to request that the processing of your data be restricted. That is the case, for example, if you dispute the accuracy of your data. You can then request the restriction of processing for the period it takes to review the accuracy of the data.
5. Right to object: If processing is based on an overriding legitimate interest, you have the right to object to the processing of your data. An objection is permitted if processing is conducted in either the public interest or based on 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.
6. Right to data portability: If data processing is based on consent or performance of a contract and the processing is performed by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format and to transmit those data to another data processor.
7. Right to withdraw consent: Where data processing is based on consent, you have the right to withdraw your consent to data processing, with future effect, at any time free of charge.
8. Right to lodge a complaint about processing of your data with a supervisory authority (such as the Data Protection Officer for the German State of Lower Saxony).

D. How to contact us

Contact persons for exercising your rights

• 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, please contact our Data Protection Officer: Volkswagen AG Data Protection Officer Berliner Ring 2, 38440 Wolfsburg, Germany dataprivacy@volkswagen.de

Version dated: April 2021