Privacy Policy Elli Charging

Thank you for using our Elli Charging mobile application (“app”). This information applies to the following services and functions, provided they are available in a country, an app version and depending on the mobile device and vehicle model.

Please find below information about the data controllers and their responsibilities (Section A), how your data is collected, processed, and utilized in connection with the use of the app for information purposes (Section B) and in connection with the use of Elli Charging (Sections C–H), as well as about your rights and contact persons (Sections I and J).

A. Data Controller, Joint Controllership

If you use the Elli Charging service (“Charging Service”), your data is being processed by Volkswagen Group Charging GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, email: info@elli.eco, entered in the Commercial Register of the District Court of Charlottenburg under No. HRB 208967 B (“Elli Germany”) and Volkswagen Group Charging CZ s.r.o., Ve svahu 482/5, Podolí, 147 00 Praha 4, Czech Republic (which Volkswagen Group Charging GmbH has appointed to provide the charging service within the Czech Republic) (“Elli Czechia”) under joint responsibility (joint controllership).

Elli Germany and Elli Czechia have entered into an agreement on the joint processing of your personal data pursuant to Art. 26(1) of the GDPR in order to define their respective responsibilities. This document provides you with key information contained in this agreement.

According to the agreement Elli Germany carries out the processing of personal data in connection with the provision of the Elli Charging in general. Elli Czechia only receives and processes your personal data if you carry out charging sessions within Czech Republic for the purpose of billing, invoicing and charging payments as described in section D II. and III. In the agreement it is also determined that Elli Germany is responsible for providing the information referred to in Articles 13 and 14 GDPR and for processing any assertion of rights by costumers. You find more information on your rights and point of contact in section I and J.

Elli Czechia and Elli Germany, known as “Elli,” are hereinafter referred to as “Elli,” “we,” or “us.”

B. General information on using the app

I. General information

Unless you register or otherwise provide us with information, we collect the data described below, which is technically necessary for us to offer you the functions of the App and to ensure the stability and security of the App:

We process this information to enable a technically functional app (e.g. by adapting the app to the needs of your device type). In addition, this information is processed to optimize the Elli-App and to guarantee the stability and security of the app and our information technology systems. The automatically collected data is not personal related and does not allow any inference to you, it is stored for 30 days and then properly deleted, unless longer storage is required or justified by law.

II. Search and find charging stations and share with Google/Apple maps

If you wish to use the search and find function for charging stations, the Google Maps (Google Inc.) map service is integrated on your device. This map service allows you to view charging stations. If you use this service, once enabled, your location is sent to the map service at the time of your query. Please note that this map service is provided to you by Google under its own responsibility. We are not responsible for data processing by Google. Privacy information for the Google Maps service may be found at https://policies.google.com/privacy?hl=de.

You can also share the charging stations described above on your device with the map service that is available or installed on your device (e.g., Apple Maps, Google Maps, etc.). If you use this function, the relevant map service will process your location at the time of sharing as well as shared destinations (e.g., an available charging station including its address). Please note that the map services are provided under the responsibility of the respective provider. We are not responsible for data processing. You can find information on data protection with regard to the map service in the privacy policy of the respective provider; this information is available at https://www.apple.com/legal/internet-services/maps/terms-de.html for Apple Maps and at https://policies.google.com/privacy?hl=de for Google Maps, for example.

If you use one of the two aforementioned services, we will store the corresponding data for technical reasons only temporarily. The legal basis for this data processing is your use of the corresponding services (Article 6, paragraph 1, letter b, GDPR). As soon as you log off, your personal data is deleted. After one year of non-use at the latest, they are deregistered for security reasons and have to register again. In this case too, the temporarily stored data will be deleted.

III. Tracking Tools

Volkswagen Group Charging GmbH uses Microsoft App Center and Firebase to collect anonymous data on the use of the software for the purpose of improving the software, the components configured with it and the services. Documented are the frequency of use of the software, individual functions, malfunctions of the software, model, version and status information of the component as well as model, operating system, language and country of the device. No personal data will be transmitted to Volkswagen Group Charging GmbH.

IV. Attribution tools

Volkswagen Group Charging GmbH uses the Adjust analytics platform for app attribution, to improve the user experience, and to optimize the scaling of the app. We collect and process the following data for this purpose:

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. For this purpose, we employ the services of the processor Adjust GmbH (“Adjust”), headquartered at Saarbrücker Str. 37a, 10405 Berlin, Germany.

V. Analytics tools

Volkswagen Group Charging GmbH uses the Amplitude analytics platform for app analytics to gain insights into the use of the app and its features. This allows us to improve your experience by implementing updates or new features tailored to your needs. The analytics platform is provided by Amplitude, Inc. (“Amplitude”), located at 201 3rd Street, Suite 200, San Francisco, CA 94103, USA. We collect and process the following data for this purpose:

Amplitude is not able to establish the identity of an individual user. We do not receive any data on individual users from Amplitude, only statistics and analyses in an overall context, which are made available to us in aggregated form via the user interface provided by Amplitude. We make no attempt to identity or track the behavior of individual users.

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists. Data is transferred to the USA when data is processed by Amplitude Amplitude is certified under the EU-U.S. Data Privacy Framework, which serves as an adequacy decision of the EU as a guarantee for third-country transfers. Beyond that, we have also concluded standard contractual clauses with Amplitude. You can request information on the content of these clauses from the contacts listed in this Privacy Policy.

You can find additional information on data processing in Amplitude’s privacy policy: https://amplitude.com/privacy

VI. Feature management with LaunchDarkly

We use the LaunchDarkly feature management platform in order to use feature flags in the app. This enables us to selectively enable and test various features in the app and thereby improve your experience and the quality of the app. For this purpose, we process user profile data (e.g., e-mail address, user ID, country) as well as app and device-specific data (e.g., app version, brand, operating system).

The associated data processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw your consent granted to Volkswagen Group Charging GmbH at any time free of charge. Go to “Your rights” in this Privacy Policy for further information on exercising your rights. We will also delete your personal data after three (3) years at the latest or when the purpose no longer exists.

For this service, we use the platform of Catamorphic Co. dba LaunchDarkly, who provides the service (“LaunchDarkly”), located at 1999 Harrison St., Suite 1100, Oakland, CA 94612 U.S. Your data will be transferred to the USA for this purpose. To this end, we have concluded EU standard contractual clauses with the service provider, which act as a guarantee for this transfer of data. You can request information on the content of these standard contractual clauses at any time from the contacts listed in Section J.

VII. Remote logging

We log your use of the app by means of the remote logging function provided as a Google Cloud service. Along with that, we also log other problems beyond crashes, bugs, or residual currents. This allows us to investigate potential problems across all devices and troubleshoot them more quickly. Our aim in using remote logging is to ensure that you can use the app free of error at all times and that all content is made available to you free of any problems. We use the Google service for this purpose, which is why the following personal data is transmitted to Google:

The client ID is randomly generated when the app is downloaded and saved on the backend. If you delete the app and download it again, a new client ID will be generated.

Processing is carried out on the basis of our legitimate interest in the functionality of our service and our app environment (Art. 6(1)(f) GDPR). Your data will be deleted once the purpose ceases to apply. You can read about your right to object and how to assert it in Sections I and J.

For this service, we employ the services of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S. (“Google LLC”) as a sub-processor. This means that data may be transferred to the USA. For more information on this, please read Google’s privacy policy: https://cloud.google.com/terms/cloud-privacy-notice?hl=en. The EU standard contractual clauses used by Google can be viewed under the following link: https://cloud.google.com/terms/eu-model-contract-clause

C. Processing of Your Data Upon Conclusion of the Agreement

I. Elli user account

To use our service in the app, you need an Elli user account. You can register directly in the Elli app in order to create and manage a profile. When you use our services, we process the data from your user account (your personal contact and identification data, such as your name and postal/e-mail address) for the purpose of fulfilling the agreement (Art. 6(1)(b) GDPR). We use Auth0 (10800 NE 8th Street, Suite 700, Bellevue, WA 98004, U.S.) to provide your account and login with your ELLI ID. Use includes the storage of personal contact and identification data, such as name and postal/e-mail address. The standard contractual clauses drawn up by the European Commission (as an appropriate guarantee for data processing in non-European countries) have been concluded regarding the transfer of personal data. We will be happy to provide you with information on the content of the standard contractual clauses on request

II. Elli Charging service (public charging)

a. Provision of a charging card

You need an RFID charging card (“charging card”) to start and stop a charging session. This is made available to you by Identa Ausweissysteme GmbH, Steinkirchring 16, 78056 Villingen-Schwenningen, Germany, on our behalf. In order to send you the charging card, our processor Identa Ausweissysteme GmbH is sent your contact details (first/last name and address). We receive the RFID assigned to your order and the charging card number from Identa Ausweissysteme GmbH so that we can assign the charging card to your user profile. You have the option of adding an additional shipping address used in the delivery of the charging card, which we will also send to Identa Ausweissysteme GmbH. The processing of data required for this purpose is carried out within the scope of fulfilling the agreement (Art. 6(1)(b) GDPR).

An RFID is stored on the card, which is used to assign it to your user account. The charging card number is printed on the card. Furthermore, no personal data, in particular your name or address, is stored in digital form on the card.

b. Selecting a tariff, payment method

To use the Elli charging service, select a tariff (“charging tariff”) and your preferred payment method. For purposes of concluding the agreement, we process your first and last name, your postal/e-mail address, and, if you entered this information, your tax identification number. You can view and manage the tariff you selected in your user profile. You can also edit the payment method and billing address saved by you. Data is processed for the purpose of fulfilling the agreement (Art. 6(1)(b) GDPR).

c. Processing of your data for purposes of payment settlement

We process the following personal data for purposes of payment settlement:

Credit card payment

Paypal

We collect the payment data in order to transfer it to the payment services. In addition to this, we also transfer the postal and e-mail address you provided to us to the payment services. The processing of data required for this purpose is carried out within the scope of fulfilling the agreement (Art. 6(1)(b) GDPR).

For payment settlement, we employ the services of J.P. Morgan Mobility Payments Solutions S.A., 161 Rue du Kiem L 8030 Strassen, Luxembourg, as the payment service provider. J.P. Morgan Mobility Payments Solutions S.A. uses your data for this specific purpose in connection with the payment service and is independently responsible for data processing. When you make payments, you are therefore subject to the privacy policy of J.P. Morgan Mobility Payments Solutions S.A., which you can view by following this link: https://www.wallet.volkswagenpayments.com/documents/file_data_privacy_customer_en-us.pdf.

When you register for Elli Charging and enter your payment details for the first time, the payment service will carry out a check to validate and authenticate them. The results of the check are sent to us by the payment service as a success or error message. We will inform you of the results of the check in the app. If we are required to request for further identification from you on behalf of the issuer of your credit card or PayPal, this may, for example, be done in the form of a text message or an e-mail code that you receive from the issuer of your credit card or PayPal and enter for authentication either in the app or on a website of the issuer of your credit card or PayPal, to which we will redirect you. Your payment details are saved in a payment storage system by the payment service provider so that you do not have to re-enter your payment details each time you carry out a charging session. If the payment service responsible for processing your payments changes, the data will be transferred from the outgoing payment service to the payment service who will be responsible for processing in the future.

In the event of non-payment, Elli – A Brand of the Volkswagen Group reserves the right to employ the services as a collection agency to take over the outstanding claim on our behalf within the scope of a dunning process. For this purpose, it may be necessary to transmit further customer-relevant data to our service provider atriga GmbH. atriga GmbH uses your data for this specific purpose as part of the claims process and is independently responsible for processing the data.

Your personal data will be handled by atriga GmbH in accordance with the applicable privacy policy. For more information please go to https://www.atriga.com/datenschutz/.

d. Managing your payment method

You can change the payment method you entered at registration later under “Payment method” in your user account. As part of this process, the same data that is transferred during registration is transmitted to our payment service provider (J.P. Morgan Mobility Payments Solutions S.A., 161 Rue du Kiem L 8030 Strassen, Luxembourg): first and last name, credit card details (credit card number, CVC code, expiration date), and postal/e-mail address. The processing of data required for this purpose is carried out in order to fulfill the agreement (Art. 6(1)(b) GDPR).

D. Processing of Your Data Within the Scope of Charging Sessions

I. Use of the charge service

You use your charging card to start or stop charging sessions at the charging station or right in your app. To manage the charging session using your app, first select a charging station in the app. Your RFID, the charging card number, and the contract number are transmitted to the charging station for authentication purposes. The charging session begins once your user ID has been authenticated. To ensure the proper functioning and handling of the charging tariff and the relevant charging sessions, we process your personal data as well as technical data in connection with the electricity supply agreement of the relevant charging tariff (including charging statistics and information on the charging process (e.g., charging volume, duration and/or start and end of a charging session), your vehicle identification number (only the first eight digits) along with the location of the charging station used (address of the charge point (EVSE))). The processing of data required for this purpose is carried out within the scope of fulfilling the agreement (Art. 6(1)(b) GDPR). Depending on the charging station you use, we employ the services of IONITY GmbH, Moosacher Strasse 84, 80809 Munich, Germany, or has-to-be GmbH, Salzburger Strasse 20, 5550 Radstadt, Austria, as the processor.

In order to offer you an end-to-end charging service, we also work with providers who perform data processing under their own responsibility. In such cases, we transmit your tariff ID which cannot be used to identify you as a person. For more information on data protection, refer to the relevant provider’s website. The following providers are part of our charging network:

II. Invoicing and settlement of accounts

Data processing for purposes of settlement of accounts and invoicing is carried out by Elli Czechia if you use charging stations within the Czechia, or by Elli Germany if you use charging stations outside the Czechia. On the basis of the charging plan and charging history data, we calculate the cost of the charging session using the charging plan you selected for purposes of settlement of accounts and invoicing.

III. Direct debits and chargebacks

Data processing for purposes of direct debits and chargebacks is carried out by Elli Czechia if you use charging stations within the Czechia, or by Elli Germany if you use charging stations outside the Czechia. We send the debit order along with the amount and a posting text that is to appear on your account statement to the relevant payment service. This text contains the accounting period and account number. If your account cannot be debited, for example, due to insufficient funds on the payment method or because the payment method has expired and is no longer valid, we will be notified of this by the payment service. The reason for the error and your ID number generated by us will be transmitted to us. In the event of a chargeback that you did not personally initiate, e.g., if a direct debit was charged back due to insufficient funds, you authorize us once more to debit your account. In the event that you initiate a chargeback or we issue you a refund, the charges for the amount in question will be reversed by the payment service. For this purpose, we transmit the following data to the payment service: the amount, the reason for the chargeback, your user ID, and the transaction ID generated by us and assigned to the charging session. The processing of data required for this purpose is carried out within the scope of fulfilling the agreement (Art. 6(1)(b) GDPR).

IV. Charge at Home (only available for chargers with connectivity features)

Please note that the use of Charge at Home services and associated online services (e.g., optimized charging at home charging stations on the basis of: power generated by solar panels based on real-time data; power generated by solar panels based on forecast data; European Power Exchange prices; flexible electricity tariffs) requires that the electrical installation, configuration, and connection of a charger be carried out in advance and, depending on the services used, other devices equipped with connectivity features.

a. Linking the charger

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that your charger is up-to-date and able to communicate, including the Wi-Fi connection or LTE mobile communications standard (so-called connectivity features), as part of the electrical installation and configuration process: device ID, brand, generation, device type, and software version (technical data).

If you want to use optional online services, you will need to authorize your charger and link it to your existing user account via a pairing code. You can then access charging statistics and information on your charging history at any time, manage and remotely control your charger (e.g., manage access options), and manage RFID charging cards (e.g., enable or disable them for use at the charger). Within the scope of using optional online services, we process the following personal and other technical data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention periods for your data and to “Your Rights” for more information on exercising your rights.

b. Linking the vehicle

We process the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that it is possible to communication with your vehicle during the electrical installation and configuration process: vehicle identification number (VIN), make, generation, model type, and software version (technical data).

If you want to use optional online services, you will need to authorize your vehicle and link it to your existing Elli user account by way of a user account with the manufacturer of your vehicle. You can then access charging settings and information on the state of the charge at any time as well as manage and remotely control your vehicles (e.g., manage access options). You also have the option of redirecting the Elli app to your user account with the manufacturer of your vehicle, logging in with this account, and registering the link with your Elli user account in this account. To create and manage a profile in order to use the optional online services, you will need a user account with the relevant manufacturer of your vehicle. Please note the detailed privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer as the responsible service provider. We process the data from your user account with the manufacturer of your vehicle (your personal contact and identification data, such as your name, address, and e-mail address) for the purpose of fulfilling the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above.

Within the scope of using optional online services, we therefore process the following personal data in order to provide and render the service described above: customer and user ID (data shared from your user account and e-mail addresses of the users you optionally unlocked). In addition, we also receive the following categories of data from your vehicle manufacturer (e.g., Volkswagen AG) for the same purpose in conjunction with the vehicle identification number (VIN) and your customer ID number:

Please note the relevant privacy policy that applies for your vehicle manufacturer. This can be viewed on the website of your vehicle manufacturer, in the information and directions on use, or on other media provided by your vehicle manufacturer.

If you want to use optional online services for intelligent charging functions (e.g., Elli Smart Charging services), your current charging settings may result in the optional online services not running optimally caused by certain vehicle modes and entries you made on the HMI vehicle control panel (charging configurations). If this is the case, we will need to carry out initial changes to the charging configuration of your vehicle. At the same time, you have the option of changing the charging configuration of your vehicle at any time to fit your requirements. If you made changes that once again affect your further use of the optional online services, we will notify you of this in the app. Please note that the optional online services may then only be used to a limited extent or they may no longer be used at all.

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention periods for your data and to “Your Rights” for more information on exercising your rights.

c. Linking other devices (with connectivity features if applicable)

We process, for example, the following device-specific technical data, which is regularly transmitted to our IT systems in encrypted form, in order to ensure that other devices (e.g., Modbus energy meters, smart meters/intelligent metering systems, home energy management systems) are able to communicate and are up to date as part of the electrical installation and configuration process: device ID, brand, generation, device type, and software version (technical data).

If you want to use optional online services, you will need to authorize your other devices and link them to your existing Elli user account by way of device-specific firmware/a device-specific web configuration. You can then access information about power generation/consumption (e.g., power consumed from solar panels/from the grid) at any time, remotely control your devices (e.g., manage access options, prioritize/deprioritize the supply of power to devices), as well as manage them (e.g., enable or disable electrical meters/measuring systems for use with the charger).

Within the scope of using optional online services, we process the following personal data in order to provide and render the following services:

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention periods for your data and to “Your Rights” for more information on exercising your rights.

d. Link to power supply contract

If you want to use optional online services that are directly linked to a power supply contract, you will need to link your electricity supplier with your existing Elli user account in the relevant customer portal of the electricity supplier using your registration data.

Within the scope of using optional online services, we process, for example, the following personal data in order to provide and render the following services: customer number, contract number, meter number, and electricity meter readings.

We process your personal data in order to fulfill the agreement (Art. 6(1)(b) GDPR) for as long as is necessary to achieve the purpose specified above. In this Privacy Policy, go to “Retention Obligations” for further information on the retention obligations for your data and to “Your Rights” for more information on exercising your rights.

E. Retention Obligations

We process your personal data for as long as is necessary for the aforementioned purposes. This is required for invoicing and settlement of accounts up to three (3) months after the agreement ends. In the event that you object to processing based on our legitimate interests, we will erase your personal data unless further processing is permitted under the relevant statutory provisions. We also delete personal data if we are obliged to do so for other legal reasons. Applying these general principles, we delete personal data immediately after the legal basis ceases to apply if it is no longer required for the stated purposes or the stated purposes cease to apply and provided that no other legal basis exists (e.g., retention periods under commercial and tax law); otherwise, the data will be deleted after the other legal basis ceases to apply.

F. Customer Support

You have the possibility to contact us and send us a request. In the event that you do so, we process the information and data you provide (including personal data) in a ticket in order to contact you and process your request (Art. 6(1)(b) GDPR). We are supported in processing the data by Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, Germany, and Majorel Berlin GmbH, Wohlrabedamm 32, 13629 Berlin, Germany, as processors. Your data is also stored and processed in our CRM system. We employ the services of Salesforce.com EMEA Limited (Floor 26 Salesforce Tower, 110 Bishopsgate, London, EC2N 4AY, United Kingdom) as the processor for this purpose. There is an adequacy decision issued by the European Commission in place for the United Kingdom, which serves as a guarantee for data transfers. Access to the information by Salesforce.com, Inc. (The Landmark @ One Market, San Francisco, CA 94105, USA) cannot be ruled out. Salesforce.com, Inc. is certified under the EU-US Data Privacy Framework, which serves as an adequacy decision as a guarantee for data transfers. In addition, Salesforce has Binding Corporate Rules in place, which are recognized by the European and British supervisory authorities as a guarantee for data transfers.

We will delete your data as soon as we have responded to your request to your satisfaction, provided there are no other retention periods (e.g., retention periods under tax law) to the contrary.

G. Data Processing by Service Providers

If service providers process personal data on our behalf, we have concluded a data processing agreement with these service providers and agreed to appropriate guarantees to ensure the protection of personal data. We also select our service providers with care. They process personal data for the sole purpose of performing their activities and are contractually bound by our instructions, have suitable technical and organizational measures in place to protect personal data, and are regularly audited by us.

I. Data processing on the Google Cloud Platform

Volkswagen Group Charging GmbH uses the Google Cloud Platform (GCP) to process the following categories of data:

This data is collected and used for the following purposes:

For this purpose, we employ the services of the processor Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, which uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google LLC”) as a sub-processor. Google LLC is certified under the EU-US Data Privacy Framework, which serves as an adequacy decision as a guarantee for data transfers.

II. Data processing at CELONIS

Volkswagen Group Charging GmbH employs the services of CELONIS to process the following categories of data:

This data is collected and used for the following purposes:

For this purpose we employ the services of processor CELONIS SE (“Celonis”), Theresienstrasse 6, 80333 Munich, Germany.

H. Data processing for purposes of analysis

I. Product development and business planning

Purpose of processing:

Categories of personal data for this purpose:

The data is processed exclusively pseudonymously for this purpose. Pseudonymization involves the removal of all direct personal identifiers (e.g., name, e-mail address, telephone number). Indirectly traceable identifiers (pseudonyms) are retained. Data is not analyzed in the analytics systems of Volkswagen Group Charging GmbH until it has been pseudonymized. At no time is a direct reference to a specific person re-established. The results of the analysis (in particular, metrics and KPIs) are fully anonymous. The processing of pseudonymous data is necessary because there are interactions between the user account and the relevant services. In such cases, the use of the pseudonym is absolutely necessary in order to link the data from the user account and the linked services on which the analysis is based. For this purpose, the data is stored and analyzed on the Google Cloud Platform and in CELONIS and Salesforce. The data processed for purposes of analysis will be deleted after thirty-six (36) months (three (3) years). This processing serves the legitimate interest of Volkswagen Group Charging GmbH to meet high customer demands in terms of the existing products and services and to be able to fulfill future requirements of our customers by means of new products and services that have yet to be developed (Art. 6(1)(f) GDPR).

II. Processing of your data for purposes of fraud prevention

Purpose of processing:

Direct and indirect personal data is analyzed in order to detect cases of fraud and abuse at an early time.

Fields containing personally identifiable information for this purpose

Fields containing personally identifiable information in the form of pseudonyms for this purpose:

The personal data that can be directly or indirectly attributed to a specific person indicated above is analyzed after registration or after concluding a subscription in order to check that the information is complete and valid. The purpose of this processing is to prevent cases of fraud and abuse. The data is processed for this purpose on the Google Cloud Platform and in Salesforce.

This processing serves the legitimate interest of Volkswagen Group Charging GmbH to prevent cases of fraud and abuse that cause major financial harm resulting from the use of invalid customer data (Art. 6(1)(f) GDPR).

I. Your rights

You can assert the following rights vis-à-vis Volkswagen Group Charging GmbH at any time at no charge. For more information on exercising your rights, please refer to Section G.

Right to information: You have the right to receive information from us (Art. 15 of the GDPR) regarding the processing of your personal data.

Right to rectification: You have the right to obtain from us the rectification (Art. 16 of the GDPR) of inaccurate or incomplete personal data concerning you.

Right to erasure: You have the right to obtain the erasure of your data if the conditions set out in Art. 17 of the GDPR are satisfied. You can then, for example, obtain the deletion of your data if it is no longer necessary in relation to the purposes for which it was collected. You can also obtain 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 obtain the restriction of the processing of your data if the requirements of Art. 18 of the GDPR are satisfied. This would be the case, for example, if you were to contest the accuracy of your data. You can then obtain the restriction of processing for a period enabling the controller to verify the accuracy of the data.

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. You also have the right to object 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 that you object to data processing, we ask that you inform us of the reasons for your objection. You also have the right to object to data processing for direct marketing purposes. This also applies to profiling to the extent that it is related to such direct marketing.

Right to data portability: If the processing of data is based on consent or on a contract and 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 it to another controller.

Right to withdraw consent: If the processing of data is based on consent, you have the right to withdraw your consent at any time at no charge with future effect.

Right to lodge a complaint: You also have the right to lodge a complaint with respect to our processing of your data with a supervisory authority (for example, the Commissioner for Data Protection and Freedom of Information of the State of Berlin).

J. Your contact persons

Who to contact to exercise your rights

If you have any questions regarding data privacy or wish to assert your rights, please contact our data protection officer at:

How to contact our data protection officer

PROLIANCE GmbH
www.datenschutzexperte.de
Leopoldstr. 21
80802 Munich

datenschutzbeauftragter@datenschutzexperte.de

When contacting the data protection officer, please specify Volkswagen Group Charging GmbH as the company to which your request refers. Please refrain from including sensitive information such as a copy of your ID with your request.

Last updated: June 2024