ONLINE VEHICLE MAINTENANCE PRIVACY POLICY
The purpose of this Privacy Policy is to inform you of the collection, processing and use of your personal data as a result of using the Online Vehicle Maintenance service.
1. Who is the data controller?
Data controller: SEAT, S.A.U. (CUPRA / SEAT), with tax identification number A-28049161
Address: Autovía A-2, Km. 585, Martorell (Barcelona)
Contact: customercare@cupraofficial.com / customercare@seat.com
2. What personal data do we process, how do we use it, what is the legal basis and for how long do we keep it?
In order to use this service, you need a SEAT/CUPRA ID user account. You can use your ID to log in to numerous SEAT, S.A.U. or third-party services (e.g. websites or apps). It serves as a central user account that allows you to manage your data. Registration requires your email address and a password selected by you. For more details, please see the data protection declaration. This can be viewed at https://seatid.vwgroup.io/data-privacy. You can manage the data in your user account at any time. If information from your user account is stored or deleted for the use of an individual function or service, when you re-enter the app, we will inform you of the information you either need to add to your ID or release for the respective function or service.
By using the Online Vehicle Maintenance service, the Entity will process your personal data for the purpose of providing information about the following maintenance requirements of your vehicle, as well as for creating predictive models to optimise the vehicle’s maintenance. These requirements include service-relevant information and the vehicle history (such as the display of maintenance requirements and service-relevant information or warning lights), arranging a service appointment with your Preferred Service Partner selected in your SEAT or CUPRA app, being directed to it and contacting the breakdown service. In addition, if you have any questions about using the service or individual functions, you can contact customer care at any time and give us your feedback.
Type of personal data: The Entity will process your personal data in accordance with the respective description of the functions or services you use. In order to do so, we take the respective data from your ID account and the associated systems of the corresponding functions or services, store them temporarily in the app and update them each time you use the app. In order to be able to display the service requirements that are relevant for your vehicle, we will need to process your vehicle information, such as your VIN, user ID and other status and diagnostic data on the vehicle components.
Legal basis: The provision of the services offered, understood as the performance of a contract (article 6.1 b) of the General Data Protection Regulation) according to the Terms & Conditions accepted by you in the My CUPRA or My SEAT app, as well as in the corresponding web app for the vehicle’s infotainment system.
Storage period: The data will be processed while you are considered a user of the Online Vehicle Maintenance service. After a period of inactivity of five years, your data will be blocked for 10 years and deleted after this period.
3. Who are the recipients of your personal data?
Your personal and vehicle data will only be disclosed to third parties in compliance with the appropriate legal obligations.
If you have selected a Preferred Service Partner, you can also manually arrange a service appointment with your Service Partner for the maintenance requirements. You can then view the status of your service appointment requests and, if necessary, be directed to your service partner. If you have given permission for relevant warnings to be sent automatically to your Preferred Service Partner, your vehicle will automatically send service appointment requests to your chosen service partner as soon as a yellow warning light or maintenance requirement is registered.
If you have sent a service appointment request to your Preferred Service Partner, the Entity will process your name, the time of your request, your contact details, your vehicle information and the subject of your service request, and will disclose this information to your preferred service partner. Please note that your preferred service partner will process your request as an independent data controller and under its own responsibility. The Entity is not responsible for the data processing carried out by your preferred service partner. Information on your preferred service partner's data protection can be found in the data protection information provided by your preferred service partner.
Finally, the Entity will provide access to your data to third parties, such as Volkswagen AG and IT service providers, acting as data processors and subprocessors for the purpose of being able to offer certain online functions and services related to your vehicle. The Entity uses data servers provided by the Volkswagen Group, which also provides maintenance and technical support for the IT systems. These third parties and Volkswagen AG suppliers will always process personal data on our behalf and according to our instructions.
Please note that if we receive an enquiry from you for which we are not responsible, we will forward your enquiry and your data to the relevant entity or commissioned party (e.g. your preferred service partner). However, we will only forward your enquiry and your data if this is necessary in order to process your request and this allows for faster and simpler processing in your legitimate interest and in our interest in providing you with the best possible service.
4. Will your personal data be sent outside the EU?
Depending on the function or vehicle model, your data may be processed on servers that contract their services outside of the European Economic Area, ensuring that your data is processed with the corresponding safeguards. In this sense, we inform you that entities such as SalesForce Inc and Microsoft Corporation process data as Volkswagen Group processors in order to provide data hosting services. All of the processing of your data will be carried out within the European Economic Area and it will receive the same level of protection as in the European Union. Your data will only be transferred to countries where a suitable level of data protection has been established by the European Commission or where additional safeguards have been applied. You can request all information on international transfers and the guarantees applied by exercising your rights through the contact channels indicated below.
5. Notifications
Relevant yellow and red warning lights, as well as other service-relevant information, will be displayed via the Notification Centre of your vehicle or via the My CUPRA/My SEAT app. For the notification and display, your vehicle information (e.g. your VIN, user ID and other status and diagnostic data on the vehicle components) is processed. If a red warning light is displayed, you can make a breakdown call in order to receive help directly from the roadside assistance service.
6. What are your rights as a data subject?
You can exercise the following rights:
Access: you can obtain confirmation from the Entity as to whether your personal data is being processed and you can access your personal data.
Rectification: you can rectify inaccurate personal data that concerns you. You also have the right to have incomplete personal data completed.
Deletion: you can request the deletion of your personal data when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, among other reasons.
Opposition: you can object to the processing of your personal data. The Entity will no longer process your personal data unless it has compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.
Restriction of processing: you can request the restriction of the processing of your personal data if one of the following grounds applies:
The accuracy of the personal data is contested by you, for a period enabling the Entity to verify the accuracy of such data.
The processing is unlawful, and you oppose the deletion of your personal data and request the restriction of its use instead.
The Entity no longer needs your personal data for the purposes of the processing, but the data is required by the data subject for the establishment, exercise or defence of legal claims.
You have objected to the processing, pending verification of whether our legitimate grounds override yours.
Portability: you can receive the personal data that you provided to the Entity in a structured, commonly-used and machine-readable format. You can also have this data transferred to another controller.
Consent withdrawal: you can withdraw your consent at any time. Your consent withdrawal will not affect the lawfulness of the processing based on your consent prior to withdrawal.
You can manage your privacy and personal data at any time in the vehicle’s infotainment system and in the User ID Portal.
You can exercise these rights by submitting a written request to SEAT, S.A.U., Autovía A-2 Km. 585, Martorell (Barcelona) or by sending an email to customercare@cupraofficial.com or to customercare@seat.com. Your request must specify the right you wish to exercise. The exercise of these rights is free of charge.
If you consider that the Entity has not processed your personal data in accordance with applicable law, you may lodge a complaint with the relevant supervisory authority.
7. Data Protection Officer
If you have any queries about data protection or wish to get in touch with our data protection officer (“DPO”), please, send an email to dataprotection@seat.es.
8. Privacy Policy changes
We may update our Privacy Policy from time to time. We encourage you to review the Privacy Policy periodically for any changes. Changes become effective when they are posted on the website/app.
Version: October 2024