A. Person in charge

We are pleased that you are visiting a website of Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, kundenbetreuung@volkswagen.de, registered in the commercial register of the Local Court of Braunschweig under the number HRB 100484 («Volkswagen AG»). In the following, we would like to inform you about the processing of your personal data by Volkswagen AG in connection with the use of the Volkswagen Seller Training Portal (hereinafter referred to as the «Portal») to carry out the Digital Experience (hereinafter referred to as «Seller Training») in the context of the market launch of the new Volkswagen vehicle (hereinafter referred to as «VW Vehicle»).
B. Processing and use of your personal data

I. Log File Processing

When you visit our portal (technically a website), we process the following log files from you:
• IP address of your device with which you access the website
• the websites you have visited on our website, and
• the website from which you are visiting us, and
• the date and time of your visit
• the operating system you are using, the web browser you are using, and the screen resolution you have set
The processing of this data is carried out in accordance with Article 6 (1) (b) GDPR. It is necessary in order to be able to display the portal properly to you and to ensure the secure operation of the portal. This data will be deleted after 30 days.

II. Participation in salesperson training

On this portal, you have the opportunity to take part in a digital sales training course, in this context your personal data will be processed. Unless otherwise specified, the processing is carried out in accordance with Article 6 (1) (b) GDPR for the purpose of participating in and conducting the Seller Training. Unless otherwise specified, we process your following personal data: title, first and last name, e-mail address, market affiliation, GRP role, company ID and user ID. For details on the processing activities, please refer to the sub-chapters.

The duration of the seller training, and therefore the period during which you will have access to the portal, will be communicated to you by their wholesale organization. After the end of the sales training, the follow-up of the event and the dismantling of the event platform will take place and all personal data will be irrevocably deleted with a period of 21 days after the end of the training, unless a shorter deletion period is specified in the subchapters and there are no other retention periods (e.g. tax retention periods) to the contrary.

As part of the provision of the portal, we are supported by the processor Avantgarde Gesellschaft für Kommunikation mbH (Atelierstraße 10, 81671 Munich, hereinafter referred to as «Avantgarde»).

a. Registration and Participation
Invitation and advance information about the Digital Experience will be sent to you by your wholesale organization. Registration to the portal takes place via the Group Retail Portal (GRP) and your existing access to it.
In order to provide you with access to the sales training, we process your title, first and last name, e-mail address, market affiliation, GRP role, company ID and user ID if available.

b. Knowledge Verification and Certificate
As part of the sales training, knowledge checks take place. In order to successfully complete the online training, all participating salespeople of a retail company must have successfully completed all knowledge checks (i.e. at least 65% correctly answered questions per review), as well as have watched the opening and closing video. In this context, in addition to your user ID, we therefore process your answers and the information whether you have successfully completed the chapters of the sales training. After completing the training, you will have the opportunity to download a certificate of participation.
For more information, please refer to the Seller Training Terms of Use.

c. Bookmark
The user has the option of making a note of the content that is of interest to him and calling it up via the dashboard during a repeated training session. For this purpose, only your user ID and the respective bookmark will be processed.

d. Learning Status
If you participate in the training in your role as a salesperson, your learning status (status, whether the training has been completed in full) will be tracked. As part of the quality management process, this will be sent to the training department of your wholesale organisation as proof of your successful participation.

e. Contact Options
During the sales training, you have the opportunity to contact us via the contact form or by e-mail, be it about technical problems or content-related questions. For this purpose, only your name, user ID or e-mail address and your request will be processed. Your data will be deleted four weeks after your request has been finally answered. In this context, Avantgarde, as our data processor, will process your technical questions via the corresponding e-mail address.

f. Voluntary Feedback
For your information, it should be noted that you can voluntarily take part in a survey at the end of the training to give feedback on the training components (content and structure). Participation is anonymous, the evaluation takes place anonymously on an aggregate level and takes place in a market/country comparison and is used to improve the quality of training.

C. Use of cookies

General information
Volkswagen AG uses various cookies on its websites. Cookies are small files containing configuration information that are stored on your device. Cookies can basically be divided into three categories. There are cookies that are essential for the functionality of the website (so-called functional cookies), cookies that increase the convenience of a visit to the website and e.g. Store your language settings (so-called comfort cookies) and cookies on the basis of which a pseudonymised user profile is created (so-called tracking cookies).
Only functional cookies are used on this portal. The processing of functional cookies is necessary to enable you to visit the website (cf. Art. 6 (1) (b) GDPR).

For more information about our cookies, please see our Cookie Policy.

D. Your rights
You can assert your following rights against Volkswagen AG at any time free of charge. For more information on how to exercise your rights, please refer to Section F.

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 obtain from us the rectification (Art. 16 GDPR) of incorrect or incomplete personal data concerning you.
Right to erasure: You have the right to request the deletion of your data if the conditions set out in Art. 17 GDPR are met. After that, you can, for example, request the deletion of your data insofar as it is no longer necessary for the purposes for which it was collected. You can also request erasure if we process your data on the basis of your consent and you withdraw that consent.

Right to restriction of processing: You have the right to request the restriction of the processing of your data if the requirements of Art. 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. For the duration of the verification of the accuracy of the data, you can then request the restriction of processing.

Right to object: If the processing  is based on an overriding legitimate interest, you have the right to object to the processing of your data. In the event of an objection, we ask you to inform us of your reasons for objecting to the processing of your data. In addition, you have the right to object to data processing for direct marketing purposes. This also applies to profiling insofar as it is related to direct marketing.

Right to data portability: If the data processing is based on consent or performance of a contract and is also carried out using automated processing, you have the right to receive your data in a structured, commonly used and machine-readable format and to transmit it to another data processor.

Right of revocation: If the data processing is based on consent, you have the right to revoke your consent at any time free of charge with effect for the future.

Right to lodge a complaint: You also have the right to complain to a supervisory authority (e.g. the State Commissioner for Data Protection of Lower Saxony) about our processing of your data.

E. Your contact persons
Contact person for exercising your rights
The contact persons for exercising your rights and further information can be found on the following website https://datenschutz.volkswagen.de.

Data protection supervisor
Our data protection officer is available to you as a contact person for data protection-related concerns:
Data Protection Officer of Volkswagen AG
Berliner Ring 2, 38440 Wolfsburg
dataprivacy@volkswagen.de

Last updated: September 2023