We Connect Go – Privacy Policy

This privacy policy is intended to inform you about how your personal data are processed by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, registered in the Register of Companies of the Brunswick District Court under No. HRB 100484 (“Volkswagen AG”), with the use of the mobile application We Connect Go (“We Connect Go app”).

I. Anonymous data collection
You can use individual services of this app without informing us who you are. In this case, no personal data will be collected, processed or used.

II. Services without login
When using the services of this app that do not require a login, your data will only be stored locally on your mobile device. If any other data need to be processed to provide these services, we refer to these in the section “Individual services without login” (see section C below).

III. Services with login
When using services that do require a login, data will be transferred to our data server where it will be processed and – depending on the service concerned – stored in your Volkswagen user account (see section D).

IV. Geo-services
The transmission of geodata is required to enable the various services within the We Connect Go app to be used (Trips, Challenges, Breakdown and Assistance, Service Partners, Fuel Monitor and Parking Space). In this context, geodata means the position data of your mobile device. Geodata will be transmitted only if this function has been activated in the We Connect Go app.

V. Sharing of data
Personal data will be shared with third parties only if this is necessary for the purpose of performing a contractual obligation, in particular for the provision of services. This is the case, for example, if the location of the vehicle is to be displayed on a map using the Google Maps service of Google Inc. (“Google”).

Further information on how data are processed by Google can be found at https://www.google.com/analytics/terms/us.html or at https://support.google.com/analytics/answer/6004245?hl=en.

We use service providers to provide the app. If service providers (‘processors’) process personal data on our behalf, we have concluded a data processing agreement and agreed appropriate guarantees on safeguarding the protection of personal data with these service providers. We select our processors with care. They process personal data exclusively for the purposes of fulfilling their responsibilities and are contractually bound by our instructions, have suitable technical and organisational measures for the protection of personal data at their disposal and are regularly monitored by us.

Personal data which arises from the provision of the app and for support purposes is processed on our behalf and in accordance with our instructions by CARIAD SE, Berliner Ring 2, 38440 Wolfsburg, Germany.

For the purposes of providing the app and individual functions, the personal data processed by CARIAD SE is stored in a web service cloud operated by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland. At Microsoft Ireland Operations Limited, the personal data is encrypted according to the agreements made with CARIAD SE and exclusively processed on data servers in the European Union. (Read) access to the information by Microsoft Corporation or subsidiaries with headquarters in a state outside of the EU/EEA cannot be ruled out. Corresponding EU standard contractual clauses for the transmission of personal data to processors have been concluded to ensure sufficient protection of your personal data. You can download the EU standard contractual clauses from the URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087.

In parallel to the above processing, the personal data processed shall be stored until calendar week 09/2023 in a Web Services cloud operated by Amazon Web Services, Inc. (“AWS”) 410 Terry Ave. North, Seattle, WA 98109, USA. The parallel storage helps secure the app functions during the web service cloud changeover. At AWS, the data is encrypted according to agreements made with us and exclusively processed on data servers in the European Union. (Read) access to the information by Amazon Web Services, Inc. with headquarters in the USA cannot be ruled out. Corresponding EU standard contractual clauses for the transmission of personal data to processors have been concluded to ensure sufficient protection of your personal data. You can download the EU standard contractual clauses from the URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087.

We use New Relic, Inc., 188 Spear Street, Suite 1,000, San Francisco, California 94105, United States, as a processor to process the performance data. It stores the performance data in data centres in Germany. As New Relic, Inc. is based in the USA, (read) access to data from the USA cannot be ruled out. Corresponding EU standard contractual clauses for the transmission of personal data to processors in third countries have been concluded to ensure sufficient protection of your personal data. You can download the EU standard contractual clauses from the following URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087.

Should different processors be used for the processing described in the following, these shall be described in the relevant sections.

VI. Notifications
The We Connect Go app sends selected notifications to the user’s mobile device (in the lock screen) via integrated app information about any new status or other information. The selection of notifications can be managed in the app settings.

The notifications can be activated and deactivated at any time in the settings of the user’s mobile device.

VII. Volkswagen ID
To use this service you need a Volkswagen ID user account provided by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, entered in the register of companies at Braunschweig district court under No. HRB 100484 (“Volkswagen AG”).

You can use the Volkswagen ID to sign into numerous Volkswagen AG services (e.g. websites and applications) or third-party services (Art. 6 (1)(b) GDPR). You also have the option of entering other personal data, e.g. your name, your address or your contact details such as phone number, to voluntarily complete your user account details in advance. Instead of having to register again, you can access the services using the data entered when you first registered. If you do this, the services will be linked to the central user account. If you add another Volkswagen AG service to the central user account, you must agree to the use of the personal data already stored in the central user account (Art. 6(1)(a) GDPR). As a rule, the personal data will only be passed on to a service if it is essential for performance of the service. If you do not agree to this, you have the option of creating a separate user account to sign into the service that you have selected.

If you use the Volkswagen ID in connection with a third party service, the data will only be passed on if this is absolutely necessary for the use of the third party’s service and the processing is therefore necessary to fulfil a contract between you and the third party, or is required to carry out pre-contractual measures, or is required for legal reasons.

Volkswagen AG uses the double opt-in process to complete registration, as well as to confirm the consent you have granted in this registration. An email will be sent to you at the email address provided requesting you to confirm.

If you have also consented to the use of your data for advertising in connection with the use of your Volkswagen ID, you can find the relevant provisions on data processing in Section II of the Volkswagen ID privacy statement.

Please refer to the comprehensive Privacy Policy for Volkswagen ID. This policy can be viewed at https://vwid.vwgroup.io/data-privacy

VIII. Analytics of data from the We Connect Go service
Volkswagen AG is constantly striving to develop new products and services and to improve the products and services it provides and the advertising for the purposes of marketing said products and services. Sound evaluation of the use of current products and services (analytics) is required for this purpose. For instance, data from the data backup and recovery and service scheduling is analysed for these purposes. Accordingly, Volkswagen AG processes data from the Volkswagen ID user account and associated services, such as

• Pseudonymous identification data (e.g. a randomly generated pseudonymous user ID)
• User account data (such as preferred partners)
• Transaction data (e.g. completed appointment scheduling, keeping appointments)
• Vehicle usage data (e.g. logbook, fill levels)
• Contract data (e.g. vehicle equipment, ongoing contracts with associated services)
• IT usage data (e.g. last logins to services, use of functions)
• Location data (e.g. truncated GPS data)

The purposes and details of the processing including the pseudonymisation as well as the respective lawful basis are described below.

1. Analysis for developing and improving products and services
For the purpose of developing new products and services (e.g. estimation of adoption rates of new products) and improving existing products and services (e.g. evaluation of adoption rates of new features), Volkswagen AG processes data from the We Connect Go App.

For stored vehicles, Volkswagen AG processes the vehicle identification number and adds further equipment data for your vehicle to the above data. If an address is available, Volkswagen AG will add socioeconomic and sociodemographic data (e.g. residential environment) to your data based on the address. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only analysed in Volkswagen AG’s analytics systems once this pseudonymisation has taken place. The direct personal link is not restored at any time. The results of the analytics (particularly metrics and figures) are completely anonymous.

The processing of pseudonymous data is necessary when there are interdependencies between the Volkswagen ID user account and connected services. In this case the use of a pseudonym is crucial to associate data from the Volkswagen ID user account and connected services.

Volkswagen AG deletes your pseudonymous data after 5 years and in accordance with the statutory requirements, for example if the purpose for which the data was collected no longer exists and there are no statutory retention obligations that prevent the data from being deleted.

Your personal data is processed based on Volkswagen AG`s legitimate interest in offering you newly developed and improved products and services (article 6, paragraph 1, letter f GDPR).

For more information about the pseudonymisation and analysis of your data for the purpose of developing and improving products and services, please also see the applicable comprehensive privacy statement of the Volkswagen ID. You can find the privacy statement via https://vwid.vwgroup.io/data-privacy. 

2. Segmentation for the purposes of advertising optimisation
This section does not apply to people permanently resident in Argentina and India.

For the purpose of improving advertising (e.g. evaluation of relevance for a specific campaign), Volkswagen AG processes data from the We Connect Go app. For stored vehicles, Volkswagen AG processes the vehicle identification number and adds further equipment data for your vehicle to the above data. If an address is available, Volkswagen AG will add socioeconomic and sociodemographic data (e.g. residential environment) to your data based on the address. Your personal data is pseudonymised as part of processing. Pseudonymisation involves the removal of all direct personal identifiers (e.g. name, email, telephone number, vehicle identification number). Indirectly traceable identifiers (pseudonyms) are retained. Data is only segmented in Volkswagen AG’s analytics systems once this pseudonymisation has taken place.

Volkswagen AG deletes your pseudonymous data after 5 years and in accordance with the statutory requirements, for example if the purpose for which the data was collected no longer exists and there are no statutory retention obligations that prevent the data from being deleted.

Your data is processed as described based on Volkswagen AG and Volkswagen Deutschland GmbH & Co. KG’s legitimate interest in providing optimised advertising tailored to the user (Article 6, paragraph 1, letter f GDPR).

Volkswagen AG will not relink the results of a segmentation to your personal data unless you consent to receiving advertising (Article 6, paragraph 1, letter f GDPR).

For more information on the analysis of pseudonymous data for the purposes of advertising optimisation, on consenting to advertising from Volkswagen AG, and on consenting to advertising from the national sales company (importer) responsible for your country, please see the detailed Privacy Policy for Volkswagen ID. This policy can be viewed at https://vwid.vwgroup.io/data-privacy. 

The individual services which do not require a login are described below.

I. Trips
When the We Connect Go app is connected to the Volkswagen DataPlug, the We Connect Go app records journey data by transferring geodata and stores this data locally on your mobile device. The route, date, time, number of kilometres travelled, duration, driving time, service life, average speed, maximum speed and approximate fuel costs (derived from the “Fuel monitor” service) are recorded along with information about the economy of your driving style. As part of this function, driving behaviour is classified as ‘economical’ or ‘non-economical’ and awarded corresponding points on the basis of the start time and end-of-journey time, engine speed, acceleration and braking habits, speed and coolant temperature. In addition, you can classify the journey as a private journey, business journey or commute to work. At the end of a journey, you can view your journeys, export them individually as PDF files using the export function, or delete them at any time. If you do not delete your journeys, they will be stored on your mobile device until you uninstall the We Connect Go app.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

II. Challenges
The ‘My challenges’ function allows you to collect more points in addition to those awarded for economical driving (see Section C. I.). This means you receive status upgrades more quickly. You decide which of the unlocked challenges you wish to complete. You can activate up to three challenges from different categories at once and pause them if necessary to start another challenge. Your progress in the paused challenge will not be lost. It is always possible to check which tasks you have completed and you can cancel a challenge at any time. ‘Discovery’ challenges are unique in that they don't have to be specially activated. All challenges in this category are constantly running in the background and use your geoposition to complete the challenge. If you execute certain challenges successfully, a new one is activated. You are also able to activate blocked challenges yourself with the number of points shown in the app. It is also possible to activate challenges from other countries while you're there (e.g. when you go on holiday) in exchange for points. What’s more, there’s a limited number of (hidden) challenges which you don't have to activate yourself. These will surprise you when you meet the relevant criteria.

The maximum scope of the parameters used to define successful completion of the individual challenges in different combinations comprises: efficient driving style, distance, speed, acceleration and braking behaviour, coolant temperature, time period, destination, engine speed, difference in altitude, number of trips and information about filling of the fuel monitor. When a challenge has been completed successfully, this remains stored on you mobile device until you deinstall the We Connect Go app.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

III. Breakdown and assistance
In an emergency, the user is able to directly call the following numbers in the We Connect Go app:

• Breakdown assistance
• Customer service

The app also gives you the option to share your location with others, e.g. by text message or by e-mail.

The location can only be transmitted if the mobile device is able to identify a valid location and if you have activated the transmission of geodata for the We Connect Go app in the settings of your mobile device. When the user dials a telephone number, a voice connection is set up. When a call is made, only your telephone number will be transmitted.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

IV. Service Partner
You can use the map to select a service partner as your favourite, have the contact data and the distance to the service partner displayed, initiate a telephone call from the We Connect Go app and use the navigation software in your mobile device to guide you to your service partner. No data regarding your selection of a favourite is automatically transmitted to the service partner.

Geodata need to be transmitted to allow the service partners in the vicinity of your current location to be displayed. You can activate and deactivate the transmission of geodata for this service at any time in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

V. Support
If you need assistance, you can contact We Connect Go Support by e-mail or telephone. If you choose the e-mail option, the following data will be transferred to your e-mail application as a pre-formulated text, providing this is stored in the We Connect Go app:

• Country & tenant
• Vehicle identification number
• Smartphone model
• Smartphone code name (only for Android devices)
• Smartphone system & version
• App version
• DataPlug serial number
• DataPlug firmware
• DataPlug version mapping table

These will help We Connect Go Support to provide optimum assistance for your inquiry and in fault elimination. You can edit the pre-formulated text in the e-mail application before it is sent, so you decide which data you make available to We Connect Go Support. When you make contact by e-mail, we also receive the e-mail address from which you contacted us in addition to the data listed above.

When the user dials “Call Support”, a voice connection is set up. When a call is made, only your telephone number will be transmitted.

The data transmitted for support purposes will be deleted by Volkswagen AG once the mandatory retention period (defined in the Volkswagen AG Customer Care Standards) has expired.

The above data will only be processed with your consent (GDPR Article 6, Paragraph 1, Sentence 1, lit. a). You have the right to revoke your consent to your data being processed at any time with effect for the future. Further details of your rights can be found in Section H of this Privacy Policy.

Our support uses processors to process your inquiries. More details on the processors used can be found under Section D.VIII.

VI. Parking Space
“Parking Space” saves the last known location of the vehicle in the We Connect Go app and displays this on a map, including the parking time. The function enables you to navigate your way to the parking space or share the vehicle location with others, e.g. via text message or e-mail. In order to determine the vehicle's parking position, the geoposition of the mobile device is stored in the We Connect Go app as soon as the connection between the vehicle and the app is separated after a trip. The parking position identified is then displayed on a map section of the Google Maps service.

You can activate and deactivate the transmission of geodata for this service at any time in the settings of the mobile device.

The last parking position identified remains stored on your mobile device until you deinstall the We Connect Go app.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

The individual services that require a login are described below.

I. My Volkswagen
If the We Connect Go app is connected to your vehicle, a new vehicle profile is automatically set up and activated for the paired vehicle on the basis of the vehicle identification number (VIN). If you wish to connect another vehicle to the We Connect Go app at a later date, another vehicle profile will be set up for this vehicle and activated. “My Volkswagen” shows you, for example, the name of the vehicle, the date it was first registered, the license plate number, when the next general inspection is due (defined by yourself) and the battery voltage. In addition, the following data are also displayed: the vehicle model (read out from the VIN), the current fuel level, the vehicle’s mileage and, with your consent, further vehicle details such as the model, model year, body colour, interior colour by comparing the VIN with a Volkswagen database (GDPR Article 6, Paragraph 1, Sentence 1, lit. a). You may revoke your consent at any time with effect for the future. In addition, the user can also store the tires on the vehicle (please refer to the section "Tires” for further information). The vehicle profiles and the related data will remain stored on your mobile device until you delete the We Connect Go app.

If the We Connect Go app connects to your e‑Golf, the following changes result. Instead of the current fuel level, the current charge level of the battery is shown.

Should a service appointment be due in the next 30 days or within the next 1,500 kilometres, a reminder about the next service appointment will be displayed. All content of the We Connect Go app is based on the currently active vehicle profile.

Unless otherwise marked, the above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

II. Service and Schedule
“Service Appointments” allows you to manage your agreed and performed service appointments locally on your smartphone.

“Service Appointments” enables you to send a service appointment request on a topic of your choice to your selected service partner. More detailed information about sending a service appointment request can be found in Section D. III.

As soon as you have been notified of an appointment by your selected service partner, “Service Appointments” enables you to enter this manually in the relevant request. Please note that your appointment will never be confirmed using the We Connect Go app. The appointment entered by you will not be transmitted to Volkswagen AG. Any changes you make or deletion of the manually entered appointment in the We Connect Go app will not be transmitted to your preferred service partner.

If an appointment is in the past, you can also add images to the appointment, e.g. the invoice. Furthermore, the app can – with your consent – set up an entry in the calendar in your mobile device.

You can use the map to select a service partner as your favourite, have the contact data and the distance to the service partner displayed, initiate a telephone call from the We Connect Go app and use the navigation software in your mobile device to guide you to your service partner. No data regarding your selection of a favourite is automatically transmitted to the service partner.

If you do not delete the entries, they will remain stored on your mobile device until you deinstall the We Connect Go app.

Geodata need to be transmitted to allow the service partners in the vicinity of your current location to be displayed. You can activate and deactivate the transmission of geodata for this service at any time in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

III. Service appointment request
If a service requirement is established on the basis of the yellow warnings and error messages determined by the We Connect Go app or due to the service intervals for inspection or oil change service, you can request an individual service appointment proposal from your preferred Volkswagen service partner stored in the menu item “Service and Schedule”. For this purpose, you have the following options:

1. Automatic service appointment request: If you give us your consent (Article 6, paragraph 1, subparagraph 1, letter a GDPR) to the automatic service appointment request for inspection and/or oil service, when a selected maintenance requirement is detected, the required vehicle and customer data is transmitted automatically (i.e. without you manually triggering it) to your preferred service partner and, where applicable, any distribution company or call centre commissioned by them. You can revoke your consent in the settings at any time with effect for the future.

2. Manual service appointment request: If you have not agreed to the automatic service appointment request feature for inspection and/or oil services in the settings of the We Connect Go app and a yellow warning, fuel or error alert and/or maintenance requirement (inspection/oil) is detected, you can consent to the sending of a service appointment request specifically for this yellow warning, fuel or error alert and/or maintenance requirement (inspection/oil) (Article 6, paragraph 1, subparagraph 1, letter a GDPR). The required vehicle and customer data is sent to your preferred Volkswagen service partner and, where applicable, any distribution company or call centre commissioned by them.

For both options, in the event that you give your consent (Article 6, paragraph 1, subparagraph 1, letter a GDPR), the following data is transmitted via the Volkswagen AG data server to the preferred Volkswagen service partner and, where applicable, any distribution company or call centre commissioned by them:

• Vehicle identification: number
• Description
• Mileage
• Brand / Model / Model year
• Engine code
• Transmission code
• Maintenance interval – Inspection service
• Maintenance interval – Oil change service
• Form of address
• Title
• First name / last name
• Telephone number
• E-mail address

If a service requirement is identified on the basis of the red warnings determined by the We Connect Go app, you have the possibility of calling breakdown assistance.

To coordinate and optimise this service, the authorised workshop will report information to process scheduling the appointment and the personal data listed above to Volkswagen AG and the official local importer/national organisation. Information on the importer/national organisation for your country can be found in the following list.

Croatia 
Porsche Croatia d.o.o.
Zagrebačka 117, 10 410 Velika Gorica
+385 1 62 69 111
+385 1 62 24 052
http://www.volkswagen.hr

Czech Republic 
Porsche Česká Republika s.r.o.
Radlická 740/113d, 158 00 Praha 5
+420 251 033 111
recepce@porsche.co.cz
http://www.porsche.co.cz/

France 
La société VOLKSWAGEN Group France (Division Volkswagen France) Société anonyme au capital de 7.750.000 Euros
11, avenue de Boursonne – BP 62, 02601 Villers-Cotterêts, RCS Soissons 832 277 370.
TVA Intracommunautaire : FR 64 602025538
+33 323 738 080
+33 323 738 020
http://www.volkswagen.fr

Germany 
Volkswagen Vetriebsbetreuungsgesellschaft mbH
Brandgehaege 8, 38444 Wolfsburg
info@volkswagen-vds.de
http://www.volkswagen.de

Greece 
Kosmocar S.A.
566-568, Vouliagmenis Ave., 16452 Argyroupoli, Athens
+30 210 998 1100
+30 210 998 1169
http://www.volkswagen.gr

India 
Volkswagen Group Sales India Private Limited
4th floor, B - Wing, Silver Utopia, Cardinal Gracious Road, Chakala, Andheri (East), Mumbai-400 099, India.
+91-22-33137000
customer.care@volkswagen.co.in 

Ireland 
Volkswagen Group Ireland Ltd.
Block C, Liffey Valley Business Campus, Dublin 22
+353 18 989 700
+353 18 989 701
http://www.volkswagen.ie

Italy 
Volkswagen Group Italia S.p.A.
Viale G. R. Gumpert 1, 37137 Verona
+39 045 8091111
http://www.volkswagen.it

Poland 
Volkswagen Group Polska Sp. z o.o.
ul. Krańcowa 44, 61-037 Poznań
+48 61 6273000
+48 61 6273047
http://www.volkswagen.pl

Portugal 
Portugal Siva - Sociedade De Importação De Veículos Automóveis, S.A
Rua do Comercio nº2, 2050-541 Vila Nova da Rainha
+351 263 407 000
+351 263 407 099
http://www.volkswagen.pt

Spain 
Volkswagen Group España Distribución
Parque de Negocios Mas Blau II, Calle de la Selva, 22, 08820 El Prat de Llobregat – Barcelona
+34 932 61 72 00
http://www.volkswagen.es

Sweden 
Volkswagen Group Sverige AB
Hantverksvägen 9, 15188 Södertälje
+46 8 5538 6500
+46 8 5503 3038
http://www.volkswagen.se

United Kingdom 
Volkswagen Group (UK) Ltd.
Yeomans Drive MK 14, 5AN Milton Keynes
+44 1908 679 121
+44 1908 601601
http://www.volkswagen.co.uk

Taiwan 
台灣福斯汽車
0800-828-818
volkswagentaiwan.online.crm@vods.com.tw
https://www.volkswagen.com.tw/

Austria 
Porsche Austria GmbH & Co OG 
Louise-Piëch-Straße 2, 5020 Salzburg
+43 662 4681-0
vwconnect.helpline@volkswagen.de
https://www.volkswagen.at

Brazil 
Volkswagen do Brasil Ltda.
Estrada Marginal Da Via Anchieta, 09823-901 Sao Bernardo do Campo
sac@volkswagen.com.br
https://www.vw.com.br/pt.html

Argentina 
Volkswagen Argentina S.A.
Centro Industrial Pacheco, A. de las Industrias 3101, B1610BKK - Gral. Pacheco, Buenos Aires - Argetina
+54 11 4317 9000 

Canary Islands 
Domingo Alonso, S.L.U.
Av. Pintor Felo Monzón, 34 Bajo 35019 Las Palmas de G.C.
+34 627 575 966
www.vwcanarias.com

Luxembourg 
Losch Import S.à.r.l.
5, rue des Joncs, L-1818 Howald
+352 2612121
http://www.volkswagen.lu

Slovakia 
PORSCHE SLOVAKIA spol.s r.o.
Vajnorska 160, 83104 Bratislava
+4212 49 262 600
kdhotline@porsche.sk
https://www.vw.sk/home

Finland 
K Auto Oy
PL 140, 01511 Vantaa Käyntiosoite: Tikkurilantie 123, 01530 Vantaa
010 5338 300

Romania 
Porsche România S.R.L. Importatorul Volkswagen în România
Bulevardul Pipera nr. 2, Clădirea "Porsche", 077190 Voluntari, Jud. Ilfov
+40 21 203 28 88
vw.contact@porsche.ro
Cod Unic de Înregistrare: RO9997007
Nr. de Înregistrare la Registrul Comerţului: J23/196/2004 

Japan 
フォルクスワーゲン グループ ジャパン 式会社（略称：VGJ）
本社 〒441-8550 愛知県豊橋市明海町5番地の10
東京事務所 〒140-0001 東京都品川区北品川4-7-35　御殿山トラストタワー18階
0120-993-199 （フォルクスワーゲンカスタマーセンター） 

South Africa 
Volkswagen of South Africa (Pty.) Ltd.
103 Algoa Road, Uitenhage 6229 South Africa
+27 86 434 737 

The personal data processed in the context of service scheduling shall be stored by salesforce.com Germany GmbH as a contract processor for Volkswagen AG if you have selected your preferred authorised workshop in one of the countries listed on the following website: 

www.myvolkswagen.net/weconnect-go/legal

It is not possible to rule out Salesforce.com, Inc. with headquarters in the US, having access to the information, so corresponding EU standard contractual clauses (a contractual arrangement approved by the European Commission according personal data the same protection for data processing in non-EU countries as in the EU) have been concluded. The data processed for contractual purposes (such as information on changes to our Terms of Use) is also protected by the BCR (Binding Corporate Rules) of Salesforce. Salesforce processes your data exclusively on our behalf and in accordance with our instructions as part of a contract data processing agreement. 

You can download the EU standard contractual clauses from the URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087. 

If you have chosen service scheduling with a preferred service partner in a country which is not included in the list, the data is also processed on a Volkswagen AG server.

If you do not consent to your data being transmitted, the service appointment request service will not be available and no data will be transmitted to a service partner.

The above data will only be processed with your consent (GDPR Article 6, Paragraph 1, Sentence 1, lit. a). You have the right to revoke your consent to your data being processed at any time with effect for the future. Further details of your rights can be found in Section H of this Privacy Policy.

For the purposes of improving our business processes and the customer functionality of Service Scheduling, optimising the customer benefits and rectifying product errors, we process your vehicle identification number, the service requirement category, the date the service lead was sent, your selected authorised workshop and the agreed service appointment and send these at your authorised workshop’s own responsibility to one of these commissioned processors. Based on this data, we obtain information on the service you had performed (e.g. maintenance), which helps enable us to evaluate the effectiveness of our service process. This data processing takes place based on our abovementioned interest (Article 6, paragraph 1, letter f GDPR). The evaluation is anonymous. The data will be deleted after three years.

IV. Statistics
The “Statistics” service statistically evaluates parameters selected for you, e.g. kilometres driven, driving time or the average efficient driving style. For this purpose, for example, date and time, mileage reading and speed are recorded. These statistics can be displayed for different time frames (day, week, month, year). Evaluation is restricted to the data stated in the services “Trips” (see C. I.), “Fuel Monitor" (see C. V.) and “Challenges” (see C. II.).

If the We Connect Go app connects to your e‑Golf, the analysis is limited to the data stated in the services ‘Journeys’ (see C. I.), ‘Charge monitor’ (see D. XI.), and ‘My challenges’ (see C. II.).

The storage period on your mobile device depends on the storage period of the services providing the data.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

V. Fuel Monitor
On many vehicle models, “Fuel Monitor” automatically identifies a refuelling stop as soon as the fuel level is increased by at least 10 litres (if refuelling is not automatically identified, you can enter it manually). This function allows you to set up and save an overview of refuelling stops, their costs and the number of kilometres driven. When the We Connect Go app connects with your DataPlug, an approximate value for the number of litres of fuel added is detected. You can manually edit this value at any time. When a refuelling stop is automatically identified, the location where you refuelled is identified using the geoposition of your mobile device, and automatically saved in the Fuel Monitor. The location can only be transmitted if the mobile device is able to identify a valid location and if you have activated the transmission of geodata for the We Connect Go app in the settings of your mobile device. If a refuelling stop is manually entered, you can store the address yourself.

If the vehicle’s fuel level drops below the limits of 10 litres and 5 litres, a prompt to refuel your vehicle will appear in the We Connect Go app under News. Furthermore, you can have a message displayed on any compatible mobile device at the defined limits by activating messages in the menu item “Settings”.

If you don’t delete the refuelling stops, they will remain stored on your mobile device until you deinstall the We Connect Go app.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

VI. Tires
The “Tires” service gives you the possibility to enter relevant information about the selected running tires (winter tires / summer tires / Nordic tires / all-season tires) – e.g. tire manufacturer, mileage, DOT date of production or the appointment for changing tires and a reminder for this. In addition, a corresponding individual service appointment can be requested with your selected Volkswagen service partner for a tire change or to buy new tires (please refer to Service Appointment Request for details of the data transmitted).

If you have activated notifications, you will be reminded of an agreed tire change appointment entered in the We Connect Go app.

If you do not delete the tire data, these will remain stored on your mobile device until you deinstall the We Connect Go app.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

VII. Data backup & recovery
The “Data Backup & Recovery” service protects you against loss of data and allows you, for example, to transfer your data to a new mobile device if you lose or exchange your old one. This service even makes it possible to change between the iOS and Android operating systems.

For this purpose, a backup copy (“Data Backup”) of the data stored in the We Connect Go app is created on the Volkswagen AG server for the following services:

• Trips
• Challenges
• Service Partner
• Service and Schedule
• My Volkswagen
• Statistics
• Fuel Monitor
• Parking Space
• Tires

The We Connect Go app settings are also transferred to the Volkswagen AG server for the same purpose.

Data is automatically transferred with your consent (GDPR Article 6, Paragraph 1, Sentence 1, lit. a) while you use the app and is encoded with SSL and HTTPS. In addition, you can also manually generate a backup copy at any time using “Data Backup” in the settings.

The backup copy on the Volkswagen AG server can be deleted using “Data Backup” & “Other Options” in the settings. If you do not make use of your right to revoke consent and have your backup copy deleted, it will be deleted in the event that you delete your Volkswagen ID. The data stored locally on your mobile device will not be affected.

The backup copy on the Volkswagen AG server will also be deleted if you have not logged in to use the We Connect Go app for a period of 12 months. You will be informed of this via email two weeks before this period elapses. If you do not log into the app and use it after you receive the email, the backup copy will be deleted without further notice once the 12 months have elapsed. The data saved locally on your device will be kept.

To minimize use of your mobile data volume, large volumes of data (> approx. 100 kB) will only be transferred over an existing Wi-Fi connection. A backup copy is generated at least once a day. To guarantee data security, the We Connect Go app can only be used with one Volkswagen ID user account and only with one device at any one time.

The above data will only be processed with your consent (GDPR Article 6, Paragraph 1, Sentence 1, lit. a). You may revoke your consent at any time in the settings with effect for the future. Further details of your rights can be found in Section H of this Privacy Policy.

VIII. Support
When support is needed, you can contact We Connect Go Support by means of a support request or by phone. If you select the option “Send support request”, the following data will be made available to We Connect Go Support for the purpose of providing optimum support in fault elimination, providing they are stored in the We Connect Go app:

• E-mail address
• Telephone number
• Country & tenant
• Model
• Vehicle identification number
• Smartphone model
• Smartphone code name (only for Android devices)
• Smartphone system & version
• App version
• DataPlug serial number
• DataPlug firmware
• DataPlug version mapping table
• Description of fault (if the field has been completed by the user)

When the user dials “Call Support”, a voice connection is set up. When a call is made, only your telephone number will be transmitted.

The data transmitted for support purposes will be deleted by Volkswagen AG once the mandatory retention period (defined in the Volkswagen AG Customer Care Standards) has expired.

The above data will only be processed with your consent (GDPR Article 6, Paragraph 1, Sentence 1, lit. a). You have the right to revoke your consent to your data being processed at any time with effect for the future. Further details of your rights can be found in Section H of this Privacy Policy.

When processing your queries, our customer support uses NTT Data Deutschland GmbH, Teleperformance Group Europe, Middle-East and Africa SAS, 21-25 rue Balzac, 75008 Paris, France, and Salesforce.com EMEA Limited as processors. We cannot preclude the possibility that the information will be accessed by Salesforce.com Inc. with headquarters in the USA. Corresponding EU standard contractual clauses for the transmission of personal data to processors in third countries (as an appropriate guarantee for data processing in non-European countries) have been concluded to ensure sufficient protection of your personal data. You can download the EU standard contractual clauses from the URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087. The personal data hosted in Europe is also protected through the conclusion of Binding Corporate Rules (appropriate guarantee on data processing in non-European countries).

If we receive an inquiry from you for which we are not responsible or competent, we will forward your inquiries and your personal data to those who are responsible or competent (e.g. your preferred authorised workshop). However, we only forward your inquiry and your personal data if this is required to process your issue and results in faster processing which is more beneficial to the customer, in your and our legitimate interest (see Article 6, paragraph 1, letter f) GDPR).

IX. Detailed vehicle data
The “Detailed vehicle data” service allows you to display data about the condition of your vehicle in the We Connect Go app by interpreting measured values collected from the control units installed in the vehicle.

This service is used to show you warning messages about your vehicle in the app.

A two-stage process must be completed to use this function:

1. Identification of the control units installed in the vehicle
First of all, the control units installed in the vehicle have to be identified and the results of this process have to be sent to Volkswagen AG via the app. This stage is needed to determine which measured values are available in your vehicle.

2. Access to and assessment of measured values
In the second step, the app uses the DataPlug to request the measured values for interpretation from the control units. This data is requested only when the ignition is switched on and the vehicle is held briefly at a standstill.

The measured values obtained are then transmitted to Volkswagen AG and interpreted. This interpretation process allows relevant measured values to be identified and displayed in the app in a way that you can understand.

In the course of this two-stage process, the following data are transmitted to Volkswagen AG and processed:

Vehicle identification number (VIN)
Control units installed in the vehicle that collect and process sensor data in the vehicle
Measured values from warning lamps

The last measured values requested by the app are temporarily stored on your mobile device. If new measured values are identical to the last set of measured values stored, no additional data will be transferred to Volkswagen AG. This helps to minimise data consumption. Volkswagen AG deletes any measured values after 30 days.

The above data will only be processed with your consent (pursuant to GDPR Article 6 (1) section 1 (a) GDPR). You have the right to withdraw your consent to the processing of your data at any time with effect for the future. When withdrawing your consent, you will be forwarded to the “Manage consent” sub-menu under the “Detailed vehicle data” menu in your Volkswagen ID user account. You can withdraw your consent under “connected apps” > “We Connect Go” > “Warning lamps”. Your data will be deleted once you have withdrawn your consent.

You can deactivate or reactivate the transmission of data in the app using the “Send vehicle data” sliding button under the “Detailed vehicle data” menu. Deactivating the transmission of data does not mean that you have withdrawn your consent.

If you connect an e‑Golf to the Volkswagen DataPlug, you may enable Volkswagen AG to process the following data:

• Interior and ambient temperature: Temperatures from your vehicle’s interior and surrounding area
• Battery data: Information from your vehicle’s battery systems
• Event entries: Your vehicle’s event entries with additional information for evaluation
• Warning lamps data: Warning lamps inform the driver of errors in the vehicle.
• Control unit data in the vehicle: Control unit data contains sensor information from the control units and allows conclusions to be drawn on the condition of components, for instance
• Vehicle identification number: Your vehicle’s identification number

The data transmitted to Volkswagen AG is collected by Volkswagen AG solely for the purposes of improving vehicle quality based on your consent (Article 6, paragraph 1, sentence 1, letter a GDPR). The use of data enables an analysis which constitutes the basis for the improvement of vehicle quality, with the aim of developing our vehicles for the customer based on the knowledge obtained. The nature of improvement depends on the results of the analyses which are intended to continually impact the vehicle development process.

You can withdraw this consent at any time in the settings. This withdrawal will lead to your data being deleted.

If you have not given Volkswagen AG your permission, the stated data shall not be transmitted to Volkswagen AG.

For further information about your rights, please refer to Section H of this Privacy Policy.

X. Trips
When a connection is established between the We Connect Go app and the Volkswagen DataPlug, the We Connect Go app will transmit geodata to record trip data and will store them locally on your mobile device. Routing, date, time, miles driven, duration, driving time, standing time, average speed, maximum speed and approximate fuel costs (derived from the “Fuel Monitor” service) and information about economical driving are recorded. Here, the parameters start time and end time, engine speed, acceleration and braking behaviour, speed and coolant temperatures are used to classify the driving style as “efficient” or “not efficient”, and rewarded with the corresponding points. In addition, you can also classify the trip as private, for business or as a journey to work. At the end of the trip, you can view these trips, export them as a PDF file with the export function, or delete them at any time. If you don’t delete the trips, they will remain stored on your mobile device until you deinstall the We Connect Go app.

You can view additional values for your vehicle (e.g. engine oil temperature, charge pressure, throttle valve position) if these are available for your vehicle. To do this, you must enable the relevant values. These are enabled using points you have collected for driving efficiently or for challenges.

The values available for your vehicle are displayed in a preview – together with the amount of points required to enable them. Once you have collected enough points to enable the relevant values, all you need to do is click on the applicable value and then confirm your choice. Once confirmed, your selected value will be shown in the journey details going forward.

If you have enough points, you can enable additional available values as described above. You can view the relevant options in edit mode.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (GDPR Article 6, Paragraph 1, Sentence 1, lit. b). Further details of your rights can be found in Section H of this Privacy Policy.

XI. Charge monitor
In the e‑Golf, ‘Charge monitor’ can automatically detect a charging process once the charge level has increased by at least 10 percent (if the charging process is not automatically detected, you can enter this by hand). This function allows you to create and save an overview of charging processes performed, their costs and the kilometres travelled. If the We Connect Go app connects to your DataPlug, an approximate percentage charged is detected automatically. You can edit this value manually at any time. When a charging process is detected automatically, the location where you have charged is detected using your device’s geolocation and automatically saved in the charge monitor. The location can only be transmitted if the mobile device has been able to detect a valid location, while you have activated the transfer of geodata for the We Connect Go app in your mobile device settings. When manually entering a charging process, you can record the address yourself.

If you do not delete the charging processes, they will remain stored on your mobile device until you uninstall the We Connect Go app.

Transmission of geodata for this service can be activated and deactivated at any time in the We Connect Go app settings and in the settings of the mobile device.

The above data will only be processed for the purpose of providing the contractual services described in the terms of use (Article 6, paragraph 1, sentence 1, letter b GDPR). Further details of your rights can be found in Section H of this Privacy Policy.

The Volkswagen partners assigned to the distribution company (importer) responsible for your country offer you advice on a range of products and services. This advice also includes demonstration, explanation and help with registration of Volkswagen AG digital products and services. For the purposes of evaluating and paying any applicable bonuses for this sales support, Volkswagen AG processes your personal data, such as

Vehicle identification number (VIN)
Registration data (country, date, time)
Preferred partner

and discloses it to the distribution company (importer) responsible for your country and your saved Volkswagen partner. The data disclosed is an obligatory prerequisite for matching registrations of digital products and services with associated vehicle deliveries. This matching allows Volkswagen AG, the distribution company (importer) responsible for your country and your saved Volkswagen partner to calculate key figures for evaluation of the sales support provided. The necessity of this data processing arises from contractual arrangements between Volkswagen AG, the distribution company (importer) responsible for your country and the associated Volkswagen partners.

The following local importers use the above reporting system:

Austria, Canary Islands, Croatia, Czechia, Finland, France, Germany, Greece, India, Ireland, Italy, Luxembourg, Mexico, Poland, Portugal, Romania, Slovakia, Spain, Sweden, Taiwan, Japan, South Africa and the UK.

Your personal data is processed for the purposes of evaluating and paying any applicable bonuses for sales support in an Amazon Web Services cloud operated by Amazon Web Services EMEA SARL (“Amazon”) in the European Union. It is not possible to rule out Amazon Web Services, Inc. with headquarters in the USA., having access to the personal data, so corresponding EU standard contractual clauses (a contractual arrangement approved by the European Commission according personal data the same protection for data processing in non-EU countries as in the EU) have been concluded. Amazon processes your personal data exclusively on our behalf and in accordance with our instructions as part of a contract data processing agreement. Corresponding EU standard contractual clauses for the transmission of personal data to processors in third countries have been concluded to ensure sufficient protection of your personal data. You can download the EU standard contractual clauses from the following URL https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32010D0087

Companies involved in processing are contractually prohibited from using data to create a direct link to a person (e.g. names, email addresses). In order to safeguard processing, Volkswagen AG has established a range of technical and organisational measures to prevent unauthorised access and processing for purposes other than those intended.

The described processing of your data is based on our legitimate interest in evaluating sales support provided by the distribution company (importer) responsible for your country and that of your saved Volkswagen partner. The basis for the processing described is a consideration of interests made within Volkswagen AG (Article 6, paragraph 1, letter f GDPR).

Volkswagen AG deletes your pseudonymised data after 15 months or in accordance with legal requirements, for instance, once the purpose for which it was collected becomes invalid and if deletion is not contrary to any other retention obligations.

Volkswagen AG is legally obliged to monitor products it put on the market on an ongoing basis throughout their life cycle in order to uncover potential defects in good time and eliminate them as quickly as possible. This includes the product monitoring and hazard prevention obligations.

Volkswagen AG is also happy to fulfil warranty and guarantee claims.

For this purpose, Volkswagen AG shall initially verify whether such claims exist or whether they are ruled out, for instance, by alterations to the construction of the vehicle (including tuning, modifications, etc.) carried out by an owner. If necessary, existing claims are handled in personal contact with you.

The following data is processed for the above purposes:

• VIN
• DataPlug serial number
• DataPlug software version
• DataPlug database version
• App version
• Country of app installation
• Device
• Operating system
• Operating system version
• VW ID
• Date of first DataPlug connection

The data is processed in the context of field observation exclusively for the purposes of rapidly detecting and closing relevant safety loopholes. Data is only processed for the specific purpose intended. Any allocation or processing of personal data beyond this, e.g. regarding the customer’s person or their contact and/or other details, is not required to achieve the legitimate interests of the data processing entities and is expressly prohibited for all data processing entities. At Volkswagen AG, only such persons entrusted with administrative tasks which are closely connected to processing for this purpose shall obtain access to personal data. Data shall only be disclosed to the competent regulatory authorities or the entities within Volkswagen AG responsible for recall, field and exchange activities shall only take place in the event of a recall or field action decided upon by Volkswagen AG’s product safety committees.

Your data is processed as described based on the legitimate interest of field analysis and product monitoring. The basis for this is a consideration of interests made within Volkswagen AG (Article 6, paragraph 1, letter f GDPR).

The data mentioned is generally deleted after five years.

1. Adobe Analytics
This app uses the web analysis service Adobe Analytics to analyse user visits to this web page. Data is processed on the basis of the consent that you have granted (Article 6, paragraph 1, letter a, GDPR).

We cannot preclude the possibility that your data will be accessed through Adobe Systems Incorporated having headquarters in the US, such that a corresponding EU standard agreement (adequate guarantees regarding the processing of data in non-European countries) was concluded. You have the right to be informed of this standard agreement in the course of the disclosure.

You can revoke your consent to the data processing indicated at any time with effect for the future by opening the settings in the More section of the tab bar under Settings and Support. Open the analytics settings in the Privacy section to revoke your consent to Adobe Analytics.

The information stored on the Adobe servers cannot be directly traced to an individual because Adobe Analytics is used with the following settings: ‘Before Geo-Lookup: Replace visitor’s last IP octet with 0’ and ‘Obfuscate IP-Removed’. The setting ‘Before Geo-Lookup: Replace visitor’s last IP octet with 0’ causes the IP address to be anonymised prior to geo-location by substituting the last octet in the IP address with zeros. For statistical analysis, the user's approximate location is added to the tracking package, which still contains the complete IP address. Before the tracking package is saved, the IP address is then replaced by a single, permanent IP address – referred to as a generic IP address – when the setting ‘Obfuscate IP-Removed’ is configured. This removes the IP address from the data record that is stored.

You may exercise the following rights vis-a-vis Volkswagen AG at any time without cost. You can obtain further information about exercising your rights at the following website: https://datenschutz.volkswagen.de. 

Right to information: You have the right to request information from us about how your personal data are processed.

Right of rectification: You have the right to request that we correct any personal data relating to you which is incorrect or incomplete.

Right to erasure: You have the right to request the erasure of your data if any of the conditions stated in GDPR Article 17 exists. You may then request, for example, the erasure of your data, providing the purpose for which they were gathered is no longer necessary. Furthermore, you may request erasure if we process your data on the basis of your consent and you revoke this consent.

Right to restriction of processing: You have the right to request restrictions on the processing of your data if the conditions of GDPR Article 18 exist. This is the case, for example, if you dispute the correctness of your data. You may request that processing is restricted for as long as it takes to examine the correctness of your data.

Right of objection: If processing is based on an overriding interest or if your data are used for the purpose of direct marketing, you have the right to object to the processing of your data. An objection is permissible if processing is either in the public interest or in the exercise of official authority or on account of a justified interest of Volkswagen AG or of any other third party. In the event of objection, you are kindly requested to notify us of your reasons for objecting to data processing. Besides this, you also have the right to object to data processing for the purpose of direct marketing. The same applies to profiling, if this is related to direct marketing.

Right to data portability: If data processing is based on consent or on the performance of a contractual obligation and this is done by way of automated processing, you have the right to receive your data in a structured, commonly used machine-readable format and to transfer them to another data processing provider.

Right of revocation: If data processing is based on consent, you have the right to revoke your consent at any time with effect for the future by notifying info-datenschutz@volkswagen.de or the contact data stated in the Legal notice. 

Right of complaint: You also have the right to lodge a complaint to a supervisory authority (e.g. the state commissioner for data protection) about the way we process your data. 

I. Your contact person: Data Protection Officer 
Our Data Protection Officer is your contact person for all issues relating to data protection and is available to help you exercise your rights. Please address your submissions to: 

Volkswagen AG Data Protection Officer 
Berliner Ring 2, 38440 Wolfsburg 
info-datenschutz@volkswagen.de

Version dated: November 2022