Volkswagen Financial Services (UK) Limited (“VWFS”) and Volkswagen Group United Kingdom Limited (“VWG”) are committed to protecting and respecting your personal information.
VWG’s trading divisions include Volkswagen UK, AUDI UK, SEAT UK, ŠKODA UK, CUPRA UK and Volkswagen Commercial Vehicles UK.
In this statement we refer to VWFS and VWG collectively as “we”, “us” or “our”, as applicable.
VWFS and VWG are both companies in the Volkswagen AG Group of companies and work together to ensure that follow up activities relating to the renewal of your finance contract(s) are performed as effectively and efficiently as possible. This is achieved, in part, by the sharing of your personal information between VWFS and VWG (and subsequently, with our franchised, authorised retailer network) when co-ordinating and managing the renewals process.
This statement describes the relationship between VWFS and VWG and our data protection responsibilities for personal information that is shared between us in respect of finance contract renewals. This statement also describes what types of information is shared about you, how it is used by us, how we share the information with others, how you can manage the information we hold and how you can contact us.
For the purposes of data protection laws, VWFS and VWG are “joint controllers” of the processing of your personal information described in this statement. This means that both businesses work together to decide why and how your personal information is processed. It also means that we are jointly responsible to you under the law for that processing.
We do not perform all processing of your personal information as joint controllers. VWFS makes decisions regarding certain processing of your personal information independently of VWG, for which VWFS is solely responsible. Similarly, VWG makes decisions for certain processing of your personal information independently of VWFS, for which VWG is solely responsible. Please visit the website of the relevant business using the table below to find out more about processing performed by each business independently.
VWFS
https://www.vwfsfleet.co.uk/data-privacy-policy/
VWG
The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of any substantial changes.
This version of our Privacy Statement is live from November 2020.
What are the processing roles of VWFS and VWG?
VWFS and VWG have different roles in connection with the processing of your information. In brief, VWFS shares your contact and contract information, (limited to the information described in the ‘what information do we receive’ section below), with VWG so that we may improve the way in which our retailer network manage our customers’ renewals opportunities (“renewals data”). As such, VWG shares your contact information with our franchised retailer network to ensure effective management of the renewals data, namely to ensure customers are made aware of their opportunities to renew their finance contract, where applicable. By return, VWG sends a report to VWFS detailing the status of any follow-up contact undertaken by the retailer network in connection with the renewal data, as well as any customer complaints relating to the renewals process.
VWFS is the business that has primary responsibility for the day-to-day handling of your personal information as it collects this information and has direct contact with you, due to your contractual relationship as a finance customer. As a result, VWFS is responsible for the following activities relating to the processing of your personal information for this purpose:
- acting as your main point of contact for any queries you may have relating to this statement;
- responding to your requests when you exercise your data protection rights and submit such requests to VWFS (see further below regarding these rights);
- making sure it has the legal grounds in place to share your personal information with VWG and that the purposes for which the information is shared complies with the data protection principles under applicable laws;
- producing this statement jointly with VWG;
- presenting this statement to you, including any updates, as required by applicable laws; and
- ensuring that the personal information it stores is secured and retained in accordance with data protection laws.
VWG ensures that the retailer network whose systems receive the renewals data have access to the most up-to-date information associated with your finance contract to discuss your renewal opportunities. VWG’s data protection responsibilities to you, therefore, include:
- making sure it has the legal grounds to use your personal information in the ways described in this statement;
- producing this statement jointly with VWFS;
- responding to your requests when you exercise your data protection rights and submit such requests to VWG (see further below regarding these rights); and
- ensuring that the personal information it stores is secured and retained in accordance with data protection laws.
The information we share between us relates to you and your finance contract. We only share, process and retain information which is necessary, relevant and adequate for the purposes described in this statement.
We share the following information about you and your vehicle:
- Name (including title)
- Telephone number
- VWFS Brand
- Retailer ID
- Lead type description
- Lead status
- Lead date
- Additional Info (URL link to VWFS finance platform)
- New/Used vehicle status
- Due date (Follow-up date)
- Data source and partner information
- Expiry date
- VWFS Lead ID
- Name of the retailer salesperson
- Any information contained in correspondence you send to us relating to this statement, including any complaints.
VWFS and VWG share this information between them so that our authorised retailer network may follow-up on the renewal of your finance contract. As such, sharing this personal information between us is not based upon your consent, but based upon our legitimate interests in ensuring renewals opportunities are managed and captured effectively by our retailer network. If this information was not shared, our retailer network would be unable to follow up finance renewals as effectively and VWFS would not receive reliable information regarding the status of such follow-up activities.
We will only process information that is necessary for the purpose, as described, for which it has been received.
Legitimate interests
We use and process your personal information where it is necessary for either VWFS or VWG to fulfil their legitimate interests, as set out below:
Processing necessary for us to support customers with the finance contract renewals process and with their enquiries associated with this process
- To facilitate the provision of information to VWG and ultimately to our authorised retailers to allow them to effectively and efficiently follow-up with you in relation to the renewal of your finance contract(s);
- To receive, manage, and respond to, correspondence you send to us;
Processing necessary for us to assess and respond to complaints, claims and regulators
- To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
- To enforce or protect our legal rights or to establish, bring or defend legal claims;
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- To monitor, manage and analyse how our authorised retailers undertake follow up communications with you, and to measure the performance of those retailers and their staff;
- To verify the accuracy and validity of information that we hold about you and create a better understanding of you as a customer;
- For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
- To detect and prevent fraud or other criminal activities;
- To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request); and
- To inform you of updates to our terms and conditions and policies.
Legal obligation
We may process your personal information to comply with our legal or regulatory requirements (for example, where we are required to disclose this information under a court order).
VWFS and VWG share this information between them and the information is subsequently shared by VWG with our authorised retailer network.
VWFS shares all the information listed above with VWG. However, VWG shares limited reporting information with VWFS comprising an ID number and the status of follow-up activities.
VWFS and VWG may also share information relating to your complaints, where it is appropriate and/or necessary to do so, so that they can be managed and resolved effectively and efficiently.
We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf including:
- IT service providers;
- lead qualification and management service providers;
- analytics service providers; and
- our legal and other professional advisors;
For information regarding the further sharing of personal information with third parties, please revisit the ‘sharing your personal information’ section of VWFS privacy policy, and the ‘how do we share this information?’ section of the VWG privacy policy.
We will also share your personal information if we have a duty to do so, e.g. in connection with a mandatory requirement from an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.
Due to the international nature of our business, there may be some instances where your information is processed, or stored outside of the UK and/or EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service(s) that they are undertaking on our behalf.
We will not hold your personal information in an identifiable format for any longer than is necessary.
Please see our respective privacy statements set out in the table above for details regarding the retention of your personal information.
You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).
You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within one calendar month of your request (or once we are in receipt of any identification documents requested).
You have the right to:
- Ask for a copy of the information that we hold about you;
- Correct and update your information;
- Withdraw your consent (where we rely on it).
- Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
- Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
- Transfer your information in a structured data file (in a commonly used and machine-readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.
You also have the right not to be subject to purely automated decisions (including profiling) where this has a significant effect on you. We do not envisage that any decisions will be taken about you in this way; however we will update this statement if this changes.
If you wish to exercise the above rights and/or manage your information, please contact VWFS in the first instance using the details below:
- By post: Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG
If you wish to contact VWG, you can do so in the following ways:
If you have any other data protection concerns or complaints, you can address them to VWFS’s Data Protection Officer at DPO@vwfs.co.uk.
If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Call: 0303 123 1113
Email: casework@ico.org.uk.