This privacy policy provides more information about the processing of your personal data in connection with the availability of the Digital Manual. The Digital Manual allows you to view the vehicle Owner's Manual in digital format in your vehicle or on the Internet.
Volkswagen AG is the responsible office for the processing of your personal data.
You can reach Volkswagen AG at the following address:
Volkswagen AG
Berliner Ring 2
38440 Wolfsburg
car-net.eu.incidents@volkswagen.de
Commercial register number HRB 100484 (Braunschweig district court)
Our data protection officer is your point of contact for all matters relating to data protection and if you wish to exercise your rights.
Please direct your enquiries to:
Data Protection Officer at Volkswagen AG
Berliner Ring 2
38440 Wolfsburg
datenschutz@volkswagen.de
To determine the correct vehicle owner's manual, the vehicle identification number (VIN) of your vehicle is sent to our data server. The VIN represents a personal data, as it is assigned to the registered keeper as a unique identification number. This also applies if and even though we do not make this allocation ourselves. The VIN is used to determine and display the owner's manual assigned to the vehicle according to model, model year, market and language. For the In-Car App, the Owner's Manual is transmitted to the vehicle and is thus available in the vehicle at all times, even if the vehicle is not connected to the data server. The legal basis for data processing is our legitimate interest in providing vehicle users with the vehicle Owner's Manual in digital format in the vehicle (Section 6(1)(f) GDPR). The VIN is not permanently stored on our data server and is automatically deleted.
The In-Car App checks at regular intervals whether there is an update of the vehicle Owner's Manual for your vehicle. For this purpose, the VIN of your vehicle is transmitted to our data server. If there are updates for your vehicle, they will be transmitted to the vehicle. The legal basis for data processing is our legitimate interest in always providing users of the vehicle with the current vehicle Owner's Manual in the vehicle (Section (6)(1)(f) GDPR). The VIN is not permanently stored on our data server and is automatically deleted.
The digital logbook in the vehicle is an in-car app. In order to comply with the current state of the art, it may be necessary to update the in-car app. As soon as you or another vehicle user triggers the software update, the following data is processed to carry out the update process: IT usage data, software version, VIN, web app identification number. The legal basis for data processing is our legitimate interest in ensuring that the Digital Manual always functions smoothly from a technical point of view (Section (6)(1)(f) GDPR). This data is stored for up to 12 months to ensure operational stability and supportability.
The SPLUNK log analysis system is used to identify and rectify problems in the provision of the Digital Manual at an early stage. When the vehicle Owner's Manual is requested by confirming the VIN entry on the website or in the course of updating the vehicle Owner's Manual in the In-Car App, log data is stored locally in SPLUNK. The following information is processed for the error analysis: VIN, time of the request, the IDs of the on-board literature belonging to the VIN, touch point of the request. The legal basis for data processing is our legitimate interest in providing users of the vehicle with the vehicle Owner's Manual in digital format both in the In-Car App and on the website (Section 6(1)(f) GDPR). The log data is stored for up to 3 months to ensure supportability and then automatically deleted. Another tool that is used for this purpose is provided by our processor, New Relic Inc., 188 Spear Street, Suite 1000, San Francisco, California 94105, USA, which stores the named data in data centres in Germany. The possibility of the information being (read) accessed by New Relic, Inc., which is domiciled in the USA, cannot be ruled out. Appropriate EU standard contractual clauses have been agreed to cover the transfer of personal data to processors in third countries to ensure that your personal data is sufficiently protected. You can access the EU standard contractual clauses via the following URL https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914.
The Digital Manual website uses various cookies. Cookies are small files containing configuration information that are saved on your terminal device. Cookies can essentially be divided into three categories. There are cookies that are essential for the functionality of the website (functional cookies), cookies that make it easier to visit a website and, for example, save your language settings (convenience cookies), and cookies on the basis of which a pseudonymised user profile is created (tracking cookies). Only functional cookies are used for the Digital Manual website.
Processing of the functional cookies is necessary to enable you to visit the web page (see Section 6(1)(b) GDPR).
Our data servers are provided by the following service providers who process your personal data on our behalf and only according to our instructions:
Audi AG
Auto-Union-Strasse 1
85057 Ingolstadt
Germany
SKODA AUTO a.s.
tř. Václava Klementa 869
293 01, Mladá Boleslav II
Czech republic
The protection of your personal data is important to us. We therefore take both technical and organisational measures in accordance with Section 32 GDPR to prevent misuse or loss of your data. For example, we will only transmit your data in encrypted form.
We will also only transfer your data to third parties via pseudonyms, insofar as this is possible without jeopardising the purpose of the processing. Recipients who process data exclusively on our behalf and according to our instructions are contractually obliged by us to comply with the data protection rules and our instructions. For this purpose, we conclude so-called order processing agreements in accordance with Section 28 GDPR with our service providers, so that your data is also subject to our high level of protection in the area of the processors.
In the In-Car App, you can set your personal privacy settings (available depending on the model) and prevent data processing.
To prevent data processing, you have the option of selecting the Maximum privacy mode in the settings. This puts your vehicle into offline mode. In offline mode, the installed vehicle owner's manual can still be used. However, it is no longer possible to check whether the vehicle Owner's Manual has been updated. Likewise, further languages of the Owner's Manual can no longer be loaded unless these languages are already pre-installed.
We do not identify you on the basis of the personal data processed. In particular, identification is not necessary for the provision of the Digital Manual. The following rights are only available to you to a limited extent in accordance with Section 11 GDPR. This means that we are only obliged to fulfil your subsequent claims if you provide us with the VIN of your vehicle when asserting your rights. This information will be deleted by us immediately after your claims have been fulfilled, unless further storage is required by law or is mandatory for evidence purposes.
We will only identify you on the Digital Manual website once you have logged in to the myVolkswagen section with your Volkswagen ID and also entered your VIN. In this case, you have the following rights. You can assert them against Volkswagen AG at any time free of charge. In order to facilitate a quick processing of your request, we kindly ask you to contact our data protection officer (see B).
More information on asserting your rights can be found at https://datenschutz.volkswagen.de.
You have the right to obtain information from us about the processing of your personal data.
You have the right to demand that we correct any incorrect or incomplete personal data that concerns you.
You have the right to request erasure of your data if the prerequisites stated in Section 17 GDPR are met. For example, you may demand that your data is erased if it is no longer necessary for the purposes for which it was collected.
You have the right to request restricted processing of your data if the requirements stated in Section 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. You can then demand a restriction of the processing of your data until its accuracy is verified.
You have the right to object to the processing of your data unless we can demonstrate that compelling legitimate grounds exist which override your interests, rights and freedoms against processing, Section 21 GDPR. If you object to the processing of your data, please notify us of the reasons for your objection.
You have the right to receive your data in a structured, commonly used and machine-readable format and to transmit this data to another person responsible for processing the data, provided that data processing is based on consent or contract fulfilment and that automated processing methods are also used. In addition, you have the right to have the personal data transmitted directly by us to another person responsible for processing the data.
You also have the right to lodge a complaint about our processing of your data at a supervisory authority (such as the Data Protection Commissioner for the State of Lower Saxony).
Version dated: September 2023