Cookie policy

Annex F: Non-binding template for cookie policy including necessary information pursuant to Art. 13,14 GDPR (Section 3 c) and Section 4 b) ) as well as Art. 26 GDPR (Section 6)

1. General Information

We, Volkswagen Group Spain Distribution (“we”, “us” or “our”) alone as a data controller or, concerning the use of Adobe Analytics, as joint controller with AUDI AG, Auto-Union-Straße 1, 85057 Ingolstadt, Germany (“Audi”) “, process your personal data, notably by way of Cookies and similar technologies (as defined below) when you are using this website.

Your personal data may also be processed by third parties through their own Cookies and similar technologies. For more information regarding such third parties, please see the Section “Third Party Cookie” below.

The Cookie Policy explains which Cookies and similar technologies we use on our website for what purposes and the options you have for managing your preferences.

On our website, we use technologies that make it easier to use our website, make our website more user-friendly and provide various features (please see Sections 3 and 4 for further details). Examples of such technologies include cookies, pixels and scripts (referred to as “Cookies”).

Cookies are small data files that are stored on your device and that contain data such as for instance personalised page settings (e.g. language, screen resolution) and login information. This data file is generated by the web server you have connected to via your web browser and then sent to you.

Please find more information on how we process your personal data, including personal data collected through Cookies, how you can execute your data protection rights and the contact details of our data protection officer in our Privacy Policy.

2. Managing Cookies

In principle, it is possible to use our website without Cookies, but the use without Cookies may alter the functioning or availability of the website. However, if you wish to make full use of our website features, you should accept Cookies that enable you to use certain features or make it more convenient for you to do so.

Most web browsers are set to allow all Cookies by default. In addition to your rights as a data subject, you can prevent the use of Cookies at any time with effect for the future by changing your browser settings so that no Cookies or only certain Cookies are allowed or so that you are notified as soon as Cookies are sent. This may mean that you cannot use all the features of our website in full.

Please bear in mind that your choices only ever affect the browser you used when you made such choices. If you use different browsers or end devices, you may need to exercise your choice regarding Cookies again. Under certain circumstances after updates, or if you delete the Cookies from your browser, the settings can be reset to the basic configuration and we may ask you to exercise your choice regarding Cookies again upon your next visit to our website.

The following links will assist you in managing your Cookies browser settings, or you can use the ‘Help’ option in your internet browser for more details:

• Internet Explorer, Microsoft Edge: http://support.microsoft.com http://support.microsoft.com
• Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies http://support.mozilla.com/en-US/kb/Cookies
• Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
• Safari: http://support.apple.com/kb/PH5042
• Opera: http://www.opera.com/browser/tutorials/security/privacy/
• Adobe (flash cookies): http://www.adobe.com/security/flashplayer/articles/lso/

There are also software products that can manage Cookies for you. You can also find further information about Cookies and how to manage Cookies on help pages on the Internet such as https://www.allaboutcookies.org/.

If you change / set your browser settings or use certain software products that block Cookies we will respect these browser settings and not send the Cookies disabled in your browser settings or via such software products. If you allow Cookies in your browser settings, we will present a Cookie Banner on our website which allows you to manage your Cookie settings, e.g. to activate certain Cookies. Cookies will only be placed if you provide your consent to the relevant Cookie category. Please note that Essential Cookies (see Section 3 below) do not require your consent and will always be placed if you allow Cookies in your browser settings.

You can withdraw your consent and change the Cookie categories selected by you at any time. Please refer to the “Cookie Settings” in the footer of the website Cookie Settings.

3. What Cookies do we use?

We generally use Cookies belonging to the following categories:

1. Storage period

Cookies may also save files for a longer period or temporarily on your device.

Permanent Cookies store a file on your end device for a particular period until the Cookie’s expiry date (or until you delete it). They store e.g. language settings so that you don’t have to configure them repeatedly for our website.

Session Cookies temporarily store a session ID while you are active on our website. This prevents you from having to login again if you change pages, for instance. Session Cookies are deleted when you log out, or lose their validity as soon as your session has expired.

1. First / Third Party Cookies

(1)        First Party Cookie

A First Party Cookie is referred to as a Cookie implemented by us as a controller (which shall have the same meaning as a responsible party in other jurisdictions) or our processors (which shall have the same meaning as an operator in other jurisdictions). The Audi entity operating the website (see imprint) is responsible for the data processing. The Audi entity operating the website processes the data collected from the First Party Cookies for its own purposes, regardless of whether it programmed the Cookie itself or implemented the Cookie of another legal entity.

(2)        Third Party Cookie

A Third Party Cookie is a Cookie that is set by a third party other than the Audi entity operating the website that you are currently visiting, for instance by our services provider. Third Party Cookies originate from various domains of third parties who can flexibly use the Cookies to track user behavior on our website and across other third-party websites outside the third party's offer (especially for user-specific advertising). When you visit a website where the advertising network places advertisements, the advertisements on that website may place a Third Party Cookie on your device. That Cookie usually stores the number of page visits and the length of time you have been there. If you revisit a website on which the advertiser's advertisement is also placed, the advertiser can recognise you by means of the Cookie and, thanks to the information collected, offer you individual advertisements of its own. While we allow third parties to access the site to install these Cookies on users' devices, we do not retain control over the time these Third Party Cookies will be stored in your devices. The data collected from the Cookie is processed by the third party for its own purposes as an individual controller pursuant to their corresponding privacy and cookies policy or as a joint controller together with us. This also includes Third Party Cookies from third party social networks, which enable to share information with the respective social networks.

1. Cookies used on this website

Below you will find a summary of the Cookies we use on our website, which is intended to inform you of the purpose and nature of the relevant Cookies as well as how long they are stored for.

(1)        Essential Cookies

(2)        Functional Cookies

(3)        Performance Cookies

4. Third Party Services
   
   
   1. Ensighten Privacy Manager
      1. General information

We use Ensighten Privacy Manager to help us manage the Cookies used on the website. Ensighten Privacy Manager uses Cookies to store information on whether or not and if so, for which categories of Cookies users have declared their consent to. In this regard the following data is processed:

• IP-address
• User agent
• URL
• Referrer URL
• Time stamp
• List of Server Calls
• Privacy Cookies
• Privacy Events

1. Purpose and legal basis of processing

The processing of personal data of the user with the help of Ensighten Privacy Manager enables us to store information on the user's declared consent. This helps us to provide additional content to users and to avoid that specific Cookies are set in case the user has not declared consent to the use of such Cookies. If we did not collect this information, we would not be able to ensure that our Cookies and website works correctly and some features of the website may not be available to you. The legal basis for such processing of personal data is our legitimate interest according to Art. 6(1)(f) GDPR. If you are located in Argentina, Belarus, Malaysia, Oman, Russia, the United Arab Emirates or Turkey, your continued use of this website constitutes your consent to the processing of personal data in the context of Ensighten Privacy Manager, as described in this Section 4. a. If you are located in Taiwan, the legal basis for such processing is Subparagraph 8, Article 19 of the PDPA, which states that “where the rights and interests of the data subject will not be infringed upon”.

Depending on your country of residence, different or additional provisions may apply in addition to the GDPR. Section 5 “Local law provisions” of this Cookie Policy provides an overview of applicable local law.

The Ensighten Privacy Manager is provided by our service provider Tagman Ltd., 2 Riding House Street, London W1W 7FA, United Kingdom, which acts as our data processor.

• Storage period

The data stored by Ensighten Privacy Manager will be deleted if the data is no longer needed for our above mentioned purposes. This is the case after three years.

1. Right to object

You have the right to object to the processing of personal data in the context of Ensighten Privacy Manager. Further information on your rights as a data subject can be found in our privacy policy – Privacy Policy.

Depending on your country of residence, different or additional rights may apply. Further information can be found in Section 6 “Specific additional data subject rights” of this Cookie policy.

1. Adobe Analytics
   1. General information

We use the analysis tool Adobe Analytics on our website. Adobe Analytics is provided by Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe Analytics uses Cookies to record and systematically evaluate the interactions of our website users. In this regard the following data will be processed:

• IP-address of the user (anonymised before being saved to database)
• Unique User ID assigned to the browser
• The user's click behavior on the Website
• The subpages the user accessed
• Browser type, URL, screen resolution
• Time stamp

The last octet of the IP-adress is obfuscated for processing steps (e.g. Geolocalisation) and finally the anonymised IP-adress is saved. The anonymized IP-address cannot be assigned to a user’s device.

1. Purpose and legal basis of processing

The processing of personal data of the user with the help of Adobe Analytics enables us and AUDI AG to analyse the browsing behavior of our users. By evaluating the acquired data we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our own website and its usability. You can still access our website if we do not have this information, but some features may not be available. In this regard, Audi is a joint controller with us as the operator of the specific Audi country website. Please see Section 10 for more information regarding joint controllership.

The legal basis for such processing of personal data is your consent according to Art. 6(1)(a) GDPR. The consent given by you applies to both Audi and us.

• Storage period

The data stored by Adobe Analytics will be anoymized as soon as you withdraw your consent. The data will be delted when it is no longer needed for our above-mentioned purposes. This is the case after 24 months.

1. Withdrawal of consent

You have the ability to prevent Adobe Analytics from collecting your information when you visit our website. You can do this either by changing your browser settings to  enable “Do Not Track” or by withdrawing your consent to the placement of Cookies in our Cookie Settings. For exercising your right to erasure, you need to provide us with your Experience Cloud ID (“ECID”). In order to retrieve the ECID, please open the page for which you want to find out the ECID directly by entering the URL (e.g. www.audi.de) in the address bar of your browser. After that, add the parameter ”?getid=ecid” (e.g. https://www.audi.de/de/brand/de.html/?getid=ecid) at the end of the URL in the address bar and press Enter. A pop-up with your ECID will appear.

5. Categories of recipients

The personal data collected and processed through use of third party services shall be made available to the third party service providers’ engineers, employees and consultants. Please see Section 4 above for information regarding the recipients of your personal data which is obtained by use of the third party services included in this Section 4. General information regarding other recipients of your personal data can be found in our privacy policy: [Link to Privacy Policy] – Privacy Policy. Adequate security and confidentiality measures are being ensured at all stages.

6. Cross-border transfer of personal data

Your personal data may be stored outside your country of residence and, as such, your personal data will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions. Where required by law, we will obtain your prior express consent for such transfer of your personal data outside your country of residence.

Further information regarding the cross-border transfer of your personal data can be found in our privacy policy: Privacy Policy.

7. Information regarding the joint controllership between Audi and its importers

For the purposes of the services “Adobe Analytics”, we and Audi jointly determine the means and purposes for each processing activity and therefore are joint controllers within the meaning of Art. 4(7), 26 GDPR.

1. Processing activities for which the parties qualify as joint controllers

We and Audi jointly process your personal data in the context of the services “Adobe Analytics”. Detailed descriptions and further information regarding each service and the associated processing activities can be found in Section 4 b. of the Cookie Policy.

1. Joint controller agreement (Art. 26(1)(2, 3), (2)(1) GDPR)

We and Audi have entered into joint controllership agreements according to which we and Audi are each responsible for compliance with specific obligations under the GDPR, as follows. This includes in particular responding to requests for exercising data subjects’ rights under GDPR and compliance with information obligations stipulated by Art. 13, 14 GDPR.

1. Consequences for data subjects

We and Audi provide the data subjects with any information referred to in Articles 13, 14 GDPR in a concise, transparent, intelligible, and easily accessible form, using clear and plain language, free of charge. For this purpose, both parties provide each other with the necessary information from their operating range.

Data subjects may exercise their rights against both us and Audi. We and Audi provide each other with any information necessary to respond to the data subject’s request.

1. Distribution of responsibilities for different services

We and Audi each are responsible for different tasks and processing activities within the framework of the joint controllership as follows:

Adobe Analytics

In the context of “Adobe Analytics”, Audi is responsible for:

• the technical integration of "Adobe Analytics" into the online platforms provided by Audi,
• the configuration and administration of "Adobe Analytics",
• data evaluation, i.e. the creation of reports based on user behavior data collected by means of "Adobe Analytics", and
• Responding to requests for data subjects' rights

contracting partner is responsible for:

• the decision whether Adobe Analytics is used and may be used,
• the establishment of a legal basis compliant with the respective applicable Data Protection Laws i.e. the request for the consent of the end user for the use of "Adobe Analytics",
• data evaluation, i.e. the creation of reports based on user behavior data collected by means of "Adobe Analytics", and
• Responding to requests for data subjects' rights

8. Contact us

Audi’s 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: delegadoprotecciondatos@volkswagengroup.es.

Audi’s 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: AUDI AG, Data Protection Officer, 85045 Ingolstadt, Germany, datenschutz@audi.de.