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“Volkswagen Financial Services South Africa (Pty) Ltd” refers to Volkswagen Financial Services South Africa (Pty) Ltd, including all its group companies, affiliates and subsidiaries from time to time (also referred to as “we”, “us”, or “our”). You acknowledge and agree that your personal data collected may be used in accordance with this Policy by Volkswagen Financial Services South Africa (Pty) Ltd, which will be regarded, individually or jointly, as the data controller in respect of such data.
This Policy applies to personal data collected in connection with products and services offered by Volkswagen Financial Services South Africa (Pty) Ltd or from other interactions with us where a link or other appropriate reference of incorporation to this Policy is made, for example, in connection with our products, websites, applications and other types of services offered by Volkswagen Financial Services South Africa (Pty) Ltd typically in electronic form, as well as other services such as customer care and warranty services, customer events, or promotions and campaigns.
We may provide additional privacy related terms in connection with a particular Volkswagen Financial Services South Africa (Pty) Ltd product or service. Such product or service specific terms prevail over this Policy to the extent of any conflict. Our products or services may also contain links to other companies’ websites and other third-party services that have privacy policies of their own. We recommend that you carefully read the privacy policies of such services. Volkswagen Financial Services South Africa (Pty) Ltd is not responsible for the privacy practices or contents of any such third-party services.
Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by an appropriate mechanism such as ticking a box stating your consent, choosing technical settings for a service, website, application or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service or application you are using.
We collect your personal data typically when you purchase our products or services, use or register our services, enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of the data that we collect on you.
Information you provide us:
When you register to our services, make a purchase, enter a sales promotion or otherwise interact with us, we may ask you to provide us with certain information such as your name, email address, street address, as well as user names, passwords and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you with the products and services you have requested or to communicate with you, as well as information uploaded by you such as location, route information, pictures etc. We may collect training data, demographic information, for example, your age, gender, postal code and language preferences.
We may also collect other information you provide, such as your consents, preferences and feedback, information relating to your devices and other such information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. Some of our services may allow you to submit information about other people, for example, if you make an order for a product that you wish us to send directly to another recipient.
Your transactions with us:
We collect or request information relating to your purchase or use of our products or services as well as your other interactions with us. Such information may include, for example, details of the queries or requests you have made, the products and services provided, purchasing details (including payments made, credit card details, billing address, credit checks and other such financial information), details of agreements between you and Volkswagen Financial Services South Africa (Pty) Ltd, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other similar contact points.
Data obtained from third parties:
In addition to the personal data we obtain from you, we may obtain, in accordance with applicable laws, certain personal data from list rental companies and other publicly available sources. This may include personal data such as credit information and address information updates.
THE PURPOSES OF PROCESSING
Volkswagen Financial Services South Africa (Pty) Ltd processes your personal data for the purposes described in this Policy and/or any additional service specific privacy information. Please note that one or more purposes may apply simultaneously.
Provision of products and services:
We may process and use your personal data to provide you the product or service you have requested, fulfil your other requests, process your order or as otherwise may be necessary to perform or enforce the contract between you and Volkswagen Financial Services South Africa (Pty) Ltd. We may also process and use your personal data to ensure the functionality and security of our products and services, to identify you, and to prevent and detect fraud and other misuses.
Development of products and services:
We may process and use your personal data to develop our products and/or services. However, for the most part we only use aggregate and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalise our offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customised content and advertising. We may combine personal data collected in connection with your use of a particular Volkswagen Financial Services South Africa (Pty) Ltd product and/or service with other personal data we may hold about you, except where such personal data was collected for a different purpose.
Communicating with you and marketing:
We may process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalised marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services or promotions to you via our own or third parties’ electronic or other services.
In addition, some of our products and services may be used to promote products and services of other companies. However, Volkswagen Financial Services South Africa (Pty) Ltd does not disclose your personal data to such companies for their marketing purposes without your prior consent.
We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregate and statistical information based on your personal data. Profiling includes automated processing of your personal data for evaluating, analysing or predicting your personal preferences or interests in order to, for example, send you marketing messages concerning products or services best suitable for you.
TRANSFERS OF YOUR PERSONAL DATA
We may disclose your personal data to third parties solely as stated below in this Policy, or as obligated by mandatory law.
Service providers and other authorised third parties:
We may transfer your personal data to authorised third parties who process personal data on behalf of Volkswagen Financial Services South Africa (Pty) Ltd for the purposes described in this Policy, such as e.g., technical, logistics and other service providers. Such parties are not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data.
We may also transfer your personal data, including heart rate data, biometrical data or other health related data, to a service partner, if you use such services where a third-party company needs to process such data for the provision of the respective service or where you separately agree that a third-party company may process your data in connection with the services or products of Volkswagen Financial Services South Africa (Pty) Ltd.
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services. In such cases we take steps to ensure that adequate protection for your personal data is provided as required by applicable laws. If you wish to know more about international transfers of your personal data, you may contact us via the contact details given below.
We may disclose and otherwise process your personal data in accordance with applicable laws to defend Volkswagen Financial Services South Africa (Pty) Ltd’s legitimate interests, for example, in civil or criminal legal proceedings.
Mergers and Acquisitions:
If we decide to sell, buy, merge or otherwise reorganise our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers, for the purposes of such transactions.
DATA CONCERNING MINORS
Volkswagen Financial Services South Africa (Pty) Ltd may seek to collect information from or engage in transactions with persons under the legal age in their respective country. Volkswagen Financial Services South Africa (Pty) Ltd’ policy is to request that minors do not make purchases or engage in other legal acts on our products and services without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.
DATA QUALITY AND RETENTION
We will take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out of date or otherwise incorrect or unnecessary personal data.
Certain Volkswagen Financial Services South Africa (Pty) Ltd products and services may allow you to manage your profile and the information in such profile. We encourage you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date. Please remember that for such electronic services where you may manage your profile, it is your responsibility to provide us with correct details as well as update the personal data you have provided us with in case of any changes.
We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws.
Volkswagen Financial Services South Africa (Pty) Ltd implements appropriate technical and organisational security measures to prevent and minimise risks associated with providing and processing personal data.
Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors, sufficient training of Volkswagen Financial Services South Africa (Pty) Ltd’ personnel involved in the processing, and other necessary measures to provide appropriate protection for your personal data against unauthorised use or disclosure. Where appropriate, we may also take back-up copies and use other such means to prevent accidental damage or destruction of your personal data.
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You acknowledge and agree to the storage of cookies, other local storage technologies, beacons and other information on your devices and to the access of such cookies, local storage technologies, beacons and information by us and by the third parties mentioned above.
You have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymise or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, or you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it.
Please note that Volkswagen Financial Services South Africa (Pty) Ltd may need to identify you and to ask for additional information in order to be able to fulfil your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.
COMPLAINT TO THE INFORMATION REGULATOR
In the event you consider Volkswagen Financial Services South Africa (Pty) Ltd’s processing activities of your personal data to be inconsistent with the applicable data protection laws or that Volkswagen Financial Services South Africa (Pty) Ltd has not sufficiently ensured the realisation of your rights, you may lodge a complaint with the South African Information Regulator, responsible for data protection matters.
The Information Regulator (South Africa)
316 Thabo Sehume Street,
Tel: 012 406 4818
Fax: 086 500 3351
THE CONTROLLER OF YOUR PERSONAL DATA AND CONTACT DETAILS
The data controllers responsible for the purposes of the applicable data protection laws are:
1. Volkswagen Financial Services South Africa (Pty) Ltd Block A
Freestone Office Park
135 Patricia Road
2. Volkswagen Financial Services South Africa (Pty) Ltd, whose webpage, application, product or service you are using (name and registered address available during the purchase or registration process)
and, as applicable,
3. Volkswagen Financial Services South Africa (Pty) Ltd which uses your personal data for its direct marketing or similar purposes (name and registered address available in the marketing material received by you).
You may contact the above-mentioned data controllers at the following address:
Volkswagen Financial Services South Africa (Pty) Ltd