A. Data controller
We are pleased that you are visiting a website of Volkswagen Group Charging GmbH, Mollstraße 1, 10178 Berlin, Email: email@example.com, registered in the commercial register of the Local Court of Charlottenburg (Amtsgericht) under No. HRB 208967 B (“Volkswagen Group Charging GmbH”), and would like to thank you for your interest in our company and our products. In the following we inform you about the collection, processing and use of your data.
B. Processing of your personal data
I. Processing of log files
Each time you use the website, your Internet browser automatically transmits certain information and we save it in what are known as log files. In particular, the following information is automatically transmitted:
- An anonymous cookie ID
- The web browser you are using
- The date and time of your visit
- Our websites that you have visited
- The website from which you came to us
- The IP address (Internet protocol address) of the end device from which the web presence is accessed
This data is processed in accordance with Article 6 (1) (f) GDPR due to our legitimate interest in being able to display the website to you properly. The data will be deleted after 14 days.
To host this website, we use the processor Shopify International Limited, Victoria Buildings, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”), which uses the processor Shopify Inc., 33 New Montgomery St. Suite 750, San Francisco, California 94105, USA (“Shopify Inc.”). Shopify Inc. fulfils the requirements of the “EU-US Privacy Shield”. The Privacy Shield agreement regulates the protection of personal data transferred from a European Union member state to the USA. It ensures that the transferred data is also subject to a level of data protection that is comparable to that in the European Union. You can access the certification of Shopify Inc. at: https://www.privacyshield.gov/participant?id=a2zt0000000TdbJAAS&status=Active. Shopify in turn uses subprocessors. You can find these at the following link: https://help.shopify.com/en/manual/your-account/privacy/GDPR/subprocessors
II. Contact and customer service
You may use the email address or telephone number provided to contact us and send us a request. In this context, we process the information and data (including personal data) provided by you in a ticket in order to contact you and process your request (Art. 6 (1) (b) GDPR). Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany supports us in the processing as the order processor.
Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, and Majorel Berlin GmbH, Wohlrabedamm 32, 13629 Berlin, support us in the processing. Your data will also be stored and processed in our CRM system. We use Salesforce.com, Inc. (The Landmark @ One Market Street, San Francisco, CA 94105, USA) as an order processor. Access to the information by Salesforce.com, Inc. cannot be ruled out, so a corresponding EU standard contract as an appropriate guarantee for data processing in non-European countries has been concluded. You can access the EU standard contractual clauses used at: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087. We will delete your data as soon as we have responded to your request to your satisfaction, unless other retention periods (e.g. tax retention periods) prevent this.
III. Processing during the order process
We process the data you provide during the order process for the purpose of fulfilment of the contract (Article 6 (1) (b) GDPR). Your personal data that is required for this includes private contact and identification data (including name, address and email address) and IT usage data (including order ID, order time) and bank details (see section on “Data processing for payment”). The online shop is provided by Shopify International Limited, Victoria Buildings, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”), which uses Shopify Inc., 33 New Montgomery St. Suite 750, San Francisco, California 94105, USA (“Shopify Inc.”) as a processor. Shopify Inc. fulfils the requirements of the “EU-US Privacy Shield”. The Privacy Shield agreement regulates the protection of personal data transferred from a European Union member state to the USA. It ensures that the transferred data is also subject to a level of data protection that is comparable to that in the European Union. You can access the certification of Shopify Inc. at: https://www.privacyshield.gov/participant?id=a2zt0000000TdbJAAS&status=Active. Shopify in turn uses subprocessors. You can find these at the following link: https://help.shopify.com/en/manual/your-account/privacy/GDPR/subprocessors
To carry out an initial assessment for installing the wallbox, we ask you questions about the spatial conditions and electricity supply when you use the online pre-check. You can save the results of your online pre-check and view them under “My Account” when you have logged in with your SEAT user account (see paragraph below). If you do not have an account yet, you need to register for a SEAT user account or otherwise you will not be able to save the results of your online pre-check.
Wallbox order and installation service
Order with your SEAT or CUPRA user account
To create and manage a profile as part of the order, you need either a SEAT ID or CUPRA ID user account from SEAT, S.A., Autovía A-2, Km. 585, Martorell (Barcelona, Spain), registered in the Register of Companies of Barcelona edition 23.662, sheet 1, page no. B-56.855 (“SEAT”). You can use the SEAT ID or CUPRA ID to sign into numerous services (e.g. websites and applications) provided by SEAT or third parties. It serves as a central user account in which you can manage your data centrally. To register, you need your email address and a password of your choice.
Ordering as a guest
Alternatively, you can order as a guest. If you choose this ordering option, you do not have to register before ordering, but we will collect and process your data required for ordering as a guest (name, address, email address and telephone number).
Ordering with support from dealer
During the ordering process, your trade/service partner will also be happy to support you. Based on your wishes and requirements, your trade/service partner will put together a shopping basket for you. Once the shopping cart has been put together, your trade/service partner can provide you with the shopping cart composition by e-mail. After clicking on the link in the e-mail, you can accept or edit the shopping basket. You can place the order as a guest or via your SEAT ID or CUPRA ID user account. A prerequisite for this is that your e-mail address is passed on to the trade/service partner. We have no influence or access to this data processing, it is carried out under our own responsibility by the respective trade/service partner and without us being able to view your personal data. At the request of the trade/service partner, we will provide him/her with the date of your order, the content and an identification number generated when the shopping basket was created for the purpose of tracking the settlement of commission payments.
Managing and cancelling your order
When ordering with a SEAT user account you can view, manage and cancel your orders under “My Account”. To do this, you can retrieve the corresponding order under “My Orders”. By clicking on “Cancel Item” you can indicate the number of items to be cancelled and give reasons for cancelling, if you wish.
When ordering as a guest, you can manage changes or cancellations to your orders via the customer service.
Home check, installation and start-up
To be able to carry out a home check at your property and at a later date, if applicable, the installation, start-up, maintenance, repair or de-installation of the wallbox, we forward your contact details (name, address, email and, if applicable, telephone number for arranging an appointment) and information about the products and services you require to our installation service partner in your region.
Installation service partners acting on our behalf:
Installation service partner
Alpiq Energie Deutschland GmbH
Alpiq E-Mobility AG
Alpiq Energia Italia S.p.A.
Calle Jacinto Benavente 2B, Planta Baja.,
28232 Las Rozas de Madrid
In this connection, the installation service partner will also collect further data from you on its own responsibility that are required for on-site installation, to which we have no access. These include, in particular, technical details such as information about the existing electricity supply and the possibility of connecting to the internet. Your data will only be used by the installation service partner for managing installation at your property and for further supporting the ongoing contract, if applicable.
To be able to deliver the hardware you have ordered, we forward your contact details (name, address, email and, if applicable, telephone number) and any further information about your order as appropriated to our logistics provider Arvato Distribution GmbH in Gottlieb-Daimler Str. 1 33428 Harsewinkel.
If you wish, delivery can alternatively also be made directly to the selected installation service partner, with the earmarked transfer of your contact and order details.
Data processing for payment purposes
For the purpose of processing the payment methods offered in this web shop (e.g. credit card), we use Adyen BV, Simon Carmiggelstraat 6–50, 1011 DJ Amsterdam, Netherlands as a payment service provider. In order to process two-factor authentication (3-D Secure) within the framework of credit card transactions, we use CardinalCommerce Corporation, 8100 Tyler Blvd., #100, Mentor, Ohio 44060, USA, (“CardinalCommerce”) as a provider. Your payment data (e.g. credit card data) and other personal data (e.g. invoice address) may be transferred to both providers as part of the payment process, insofar as these are necessary for processing the payment. Adyen BV and CardinalCommerce process your data independently within the framework of bank services and are therefore independently responsible for the data. For the purpose of detecting fraud, Adyen also processes your personal data (e.g. name, invoice and/or delivery address, email and telephone number) in its capacity as our processor. You can find further information regarding data privacy for Adyen at www.adyen.de and for CardinalCommerce at https://usa.visa.com/legal/privacy-policy.html.
Start-up and configuration of the wallbox
When you purchase your SEAT Charger, you can choose between models with Wi-Fi connection or LTE mobile phone standard. To ensure that your SEAT Charger is capable of communicating and is up to date (including Wi-Fi connection or LTE mobile phone standard), the charger will at regular intervals transfer the following encrypted device-specific data to the IT systems of Volkswagen Group Charging GmbH, where it will be processed: device identification, brand, generation, device type and software version.
If you want to use additional online services (control and analysis of charging cycles) in connection with your SEAT Charger, the charger needs to be linked to your existing SEAT or CUPRA user account. In the context of using the online services, the following personal and other device-specific data is transferred to the IT systems of Volkswagen Group Charging GmbH and processed there: customer identification, statistics, charging history information, status, connection status and time stamp of the last communication connection.
Alternatively, you can also select a device without connectivity functions. If you decide in favour of this variant of the SEAT Charger, no data will be transmitted to the IT systems of Volkswagen Group Charging GmbH.
IV. Declaration of consent to use of data for advertising
If you would like to receive information about our products, you can authorise the corresponding advertising. For this purpose, the following data is processed in order to send you advertising within the scope of the consent to be given by you (Art. 6 (1) (a) GDPR): surname, first name, email address and telephone number.
Once you have withdrawn your consent, your personal data will be deleted, unless other retention periods (e.g. tax retention periods) prevent this.
Volkswagen Group Charging GmbH uses various cookies on its websites. Cookies are small files with configuration information, which are stored on your terminal device. Cookies can be divided into three categories. There are cookies which are essential to the functionality of the website (function cookies), cookies which increase the convenience of using the website and, for example, save your language settings (convenience cookies) and cookies used to create a pseudonymous user profile (tracking cookies).
The processing of function cookies is necessary to enable you to visit the website (see Art. 6 (1) (b) GDPR).
The legal basis for convenience cookies is a legitimate interest (Art. 6 (1) (f) GDPR). Providing convenience when visiting the website is a legitimate interest.
Tracking Cookies are only set if the website visitor has given their consent (Art. 6 (1) (a) GDPR). Consent must be given by using the cookie banner, which must be actively clicked on.
You can find an overview of the cookies currently used at: https://www.shopify.com/legal/cookies
You can revoke your consent to the data processing described above, which uses the specified cookies and tracking tools, at any time with future effect by clicking on the following link and changing your currently set preferences in our Cookie Consent Manager.
[Manage my cookie preferences]
D. Your rights
You can assert your following rights via-à-vis Volkswagen Group Charging GmbH at any time free of charge. You can find further information on exercising your rights under Section E.
Right of access: You have the right to obtain information from us (Art. 15 GDPR) about the processing of your personal data.
Right to rectification: You have the right to demand from us the rectification (Art. 16 GDPR) of any inaccurate or incomplete data concerning yourself.
Right to erasure: You have the right to demand the erasure of your data provided the conditions specified in Art. 17 GDPR are met. You can, for example, demand the erasure of your data provided they are no longer necessary in relation to the purposes for which they were collected. You can also demand erasure if we process your data on the basis of your consent and you withdraw this consent.
Right to restriction of processing: You have the right to demand the restriction of the processing of your data if the conditions of Art. 18 GDPR are met. This is, for example, the case if you dispute the accuracy of your data. You can then demand the restriction of processing during the verification of the accuracy of your data.
Right to object: If the processing is based on an overwhelming legitimate interest, you have the right to object to the processing of your data. An objection is admissible if the processing is either in the public interest or on the basis of a legitimate interest of Volkswagen Group Charging GmbH or a third party. In the event of an objection, please give us the reasons why you object to the data processing.
In addition, you have the right to object to data processing for the purposes of direct advertising. This also applies to profiling if it is connected with direct advertising.
Right to data portability: If the data processing is based on consent or on a contract and the processing is also carried out 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 controller.
Right of revocation: If the data processing is based on consent, you have the right to withdraw your consent with effect for the future at any time free of charge.
Right to complain: You also have the right to complain to a supervisory authority (e.g. to the Data Protection Officer Berlin or the Information Commissioner's Office in the UK (https://ico.org.uk/)) about our processing of your data.
Rights in relation to automated decision making do not apply as we do not carry out any automated decision making.
E. Your contact
Contact for the exercise of your rights
To exercise your rights and for further information please contact firstname.lastname@example.org by email or write to the Data Protection Officer of Volkswagen Group Charging GmbH, Mollstraße 1, 10178 Berlin.
Data Protection Officer
Our Data Protection Officer is available as a contact to answer your privacy-related concerns:
Data Protection Officer of Volkswagen Group Charging GmbH
Mollstraße 1, 10178 Berlin
As at: June 2020