Privacy Policy for PowerCo SE Fanpages

A. Persons responsible for processing your personal data

Thank you for choosing to visit a PowerCo SE social media page. PowerCo SE, Berliner Ring 2, 38440 Wolfsburg, Germany, kundenbetreuung@volkswagen.de, is listed in the Commercial Register of Braunschweig District Court under HRB No. 100484 (“PowerCo SE”). PowerCo SE runs its own social media pages together with the administrators of the following social media platforms:

In the following, we will provide you with information on how PowerCo SE processes the personal data which is collected when you visit our social media pages. The administrator of each social media platform is solely responsible for the processing of personal data on the social media platform itself on which our social media pages are hosted (for more information about the processing of your personal data by the administrators of social media platforms, see point II of section B).

B.   Processing of your personal data

1. Processing of your personal data by PowerCo SE

When you visit of one PowerCo SE’s social media pages, we, as the administrator of the social media page, process your actions on and interactions with our social media page (e.g. the content of the messages, queries, posts or comments that you send to us or leave on our social media pages or if you like or share our posts) and your publicly visible profile data (e.g. your name and profile picture). The personal data that is publicly visible from your profile depends on your profile settings, which you can adjust in settings on the social media platform itself (for more information about this, see point II of section B). In general, you should not use social media platforms to transmit any sensitive data or confidential information (e.g. application documents, bank or payment details). We recommend that you use a more secure means of transmission for this purpose (e.g. letter, email). As part of running our social media pages, we process the aforementioned data for the purpose of providing information about us and our products and communicating with our followers and fans. This data processing is carried out on the basis of our aforementioned legitimate interests (Article 6(1)(f) of the General Data Protection Regulation (GDPR)) and, where necessary, in order to respond to the messages, queries, posts or comments that you send to us (Article 6(1)(b) GDPR). We check whether comments or other interactions on our social media pages infringe applicable law or the relevant community guidelines, and delete infringing comments where necessary. In the event that infringing comments are made frequently, we may, under certain circumstances, process the usernames involved for the purpose of internal coordination. This processing is based on our legitimate interest (Article 6 (1) (f) GDPR) in providing a reputable online presence and satisfying legal requirements.

You can submit a test drive request and/or a request for a quote via our social media channels. For this, we process the contact details you provide (surname, first name, address, e-mail address and telephone number) and your desired vehicle model. We forward your request to the Volkswagen partner you have selected in order to process it and execute the test drive. In accordance with your request, your VW partner processes the details you have provided in order to contact you to schedule an appointment, or to fulfil or initiate a contract with you (Article 6 (1) (b) GDPR).

The social media platforms also provide us with anonymised usage statistics (known as analytics services or page insight data) from our social media pages based on the actions and interactions of our followers (e.g. likes, shares, comments etc., number of followers, page views by section, reach of a post and statistics on followers by age, language, source or interests). These statistics help us to stay in contact with our followers and fans, understand the usage and reach of our posts, evaluate content and identify usage preferences as well as allowing us to design our social media pages to be as target group-appropriate as possible. We have no influence or involvement in the creation and processing of these usage statistics or the underlying data. These statistics are created and processed at the sole responsibility of the administrator of the social media platform in question and we are unable to view the personal data of individual followers or users (for more information on this, see point II of section B). This data processing is carried out on the basis of our aforementioned legitimate interests (Article 6 (1) (f) GDPR).

We also use these anonymised usage statistics to deliver targeted interest-based advertising on the social media platforms we use or to promote our posts. The delivery of interest-based advertising and the promotion of posts on the social media platforms we use are based on an analysis of the user’s previous usage behaviour by the social media platform in question and we are unable to view the personal data of individual users, combine such personal data with any personal data we may process or identify the users to which interest-based advertising is delivered (for more information on this, see point II of section B). This data processing is carried out on the basis of our aforementioned legitimate interests (Article 6 (1) (f) GDPR). If, in exceptional cases, we were to carry out an enhanced comparison with customer lists to be uploaded by us to the social media platform in question in the context of interest-based advertising, this would only be done on the basis of your consent (Article 6(1)(a) GDPR). 

We only process your personal data for as long as it is needed for the aforementioned purposes. If you object to the processing in pursuit of our legitimate interests (Article 6(1)(f) GDPR), we will delete personal data unless its further processing is permitted in accordance with the relevant legal requirements. We shall likewise delete personal data if we are obliged to do so for other legal reasons. In accordance with these general principles, we usually delete personal data as soon as the legal basis no longer exists, if it is no longer necessary for the stated purposes or if the stated purposes no longer apply and if no other legal basis exists (e.g. retention periods under commercial and fiscal law), or otherwise when the other legal basis no longer applies.

In the context of providing our social media pages, we work with service providers (e.g. IT service providers, advertising and content agencies, and recruitment agencies, which assist us with the creation of our posts, the provision and optimisation of our social media pages and recruitment). Insofar as these service providers process personal data on our behalf, we have concluded data processing agreements with them and have agreed appropriate guarantees to ensure that personal data is protected. We also select our service providers with great care; they process personal data exclusively for the purpose of fulfilling their tasks; they are bound contractually by our instructions; they use suitable technical and organisational measures to protect personal data and they are regularly inspected by us. The service providers we use to help us provide our social media pages include 

  1. C3 Creative Code and Content GmbH, Heiligegeistkirchplatz 1, 10178 Berlin, Germany;
  2. PHD Germany GmbH, Hanauer Landstrasse 182A, 60314 Frankfurt, Germany

In other respects, we transfer your personal data to third parties (e.g. Volkswagen dealerships, authorised workshops or importers, financing service providers, transport service providers, cooperation partners etc.) only insofar as you have given us your consent to do so or this is absolutely necessary to fulfil a contract with you or to safeguard our legitimate interests (Article 6 (1) (a), (b) and/or (f) GDPR). 

2. The processing of your personal data by the administrator of the relevant social media platform

The administrator of each social media platform has sole responsibility for the processing of personal data on the social media platform itself on which our social media pages are hosted. The administrator processes personal data from you when you visit one of our social media pages, generally regardless of whether you have a user account on the relevant social media platform or are logged into the relevant social media platform and generally also uses cookies and other storage and (in some cases cross-device) tracking technologies. For more information about the processing of your personal data by the administrator of the relevant social media platform, see the information on data protection on the following web pages of each social media platform:

  1. Instagram privacy policy at https://help.instagram.com/519522125107875,
  2. Facebook data policy at https://www.facebook.com/policy,
  3. LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy,
  4. XING privacy policy at https://privacy.xing.com/de/datenschutzerklaerung, 
  5. Kununu privacy policy at https://privacy.xing.com/de/datenschutzerklaerung, and
  6. YouTube privacy policy at https://policies.google.com/privacy?hl=en. 

The social media platforms also provide us with anonymised usage statistics (known as page insight data) from our social media pages based on the actions and interactions of our followers (for more information on this, see point I of section B). We have no influence or involvement in the creation and processing of these usage statistics or the underlying data. These statistics are created and processed at the sole responsibility of the administrator of the social media platform in question and we are unable to view the personal data of individual followers or users. It is possible that the social media platforms may also create their own personalised usage statistics, for example for their own market research, advertising, or other business purposes, as part of which they may also process personal data outside the European Union, in which we likewise have no influence or involvement. For more information about the processing of your personal data by the administrator of the relevant social media platform in the context of the creation and processing of usage statistics, see the information on usage statistics on the following web pages of each social media platform:

  1. Instagram insights at https://help.instagram.com/788388387972460?helpref=faq_content,
  2. Facebook information on page insight data at https://www.facebook.com/help/pages/insights,
  3. LinkedIn privacy policy (aggregated insights) at https://business.linkedin.com/de-de/sales-solutions/sales-insights,
  4. XING privacy policy (aggregated insights) at https://privacy.xing.com/de/datenschutzerklaerung/druckversion,
  5. Kununu privacy policy (aggregated insights) at https://privacy.xing.com/de/datenschutzerklaerung/druckversion,
  6. YouTube insights at https://support.google.com/youtube/answer/9002587?hl=de&co=GENIE.Platform%3DDesktop. 

For more information about the processing of your personal data by the administrator of the relevant social media platform in the context of interest-based advertising and about how to change your profile settings and advertising preferences, see the following web pages of each social media platform:

  1. Instagram at https://business.instagram.com/advertising or https://help.instagram.com/478880589321969/?helpref=hc_fnav,
  2. Facebook at https://www.facebook.com/business/ads or https://www.facebook.com/adpreferences/ad_settings,
  3. LinkedIn at https://www.linkedin.com/psettings/advertising-data,
  4. XING at https://privacy.xing.com/de/datenschutzerklaerung/informationen-die-wir-auf-grund-ihrer-nutzung-von-xing-automatisch-erhalten/messung-und-optimierung-von-werbung,
  5. Kununu at https://privacy.xing.com/de/datenschutzerklaerung/informationen-die-wir-auf-grund-ihrer-nutzung-von-xing-automatisch-erhalten/messung-und-optimierung-von-werbung,
  6. YouTube at https://www.youtube.com/intl/ALL_de/ads/.

3. Transferring personal data to third countries

For the purposes of the aforementioned data processing, PowerCo SE also transmits your personal data to recipients domiciled outside the EU/EEA. PowerCo SE agrees EU standard contractual clauses with these recipients in order to ensure that your personal data is adequately protected. If required by the applicable data protection legislation, other protective measures (such as encryption and additional contractual provisions) are also put in place in order to ensure that your personal data is adequately protected.

You can access the EU standard contract provisions used via the URL https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX%3A32010D0087.

C.   Your rights

You have the following rights:

Right of access/information: You are entitled to information (Article 15 GDPR) relating to the processing of your personal data.

Right to rectification: You have the right to request the rectification (Article 16 GDPR) of any inaccurate or incomplete personal data concerning yourself.

Right to erasure: You have the right to have your data erased if the conditions set out in Article 17 GDPR are met. According to this, you can demand, for example, that your data is erased if it is no longer necessary for the purposes for which it was collected. In addition, you can demand erasure if your data is processed on the basis of your consent and you withdraw this consent.

Right to restriction of processing: You have the right to demand a restriction of the processing of your data if the conditions set out in Article 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. You can demand restriction of processing for the period during which the accuracy of the data is being checked.  

Right to object: If processing is based on an overriding legitimate interest, you have the right to object to the processing of your data. Furthermore, you have the right to object to data processing for the purposes of direct marketing. This also applies to profiling where this is connected to direct marketing.

Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and to transfer the data to another data processor, provided that data processing is based on consent or contract fulfilment and that automated processing methods are used.

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

Right of complaint: You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority (such as the Data Protection Officer for the State of Lower Saxony [Landesbeauftragte für den Datenschutz Niedersachsen]). You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority (such as the Data Protection Commissioner for the State of Lower Saxony [Landesbeauftragte für den Datenschutz Niedersachsen]).

With regard to data processing by PowerCo SE, you may assert your aforementioned rights vis-à-vis PowerCo SE free of charge at any time. With regard to data processing by the administrator of the relevant social media platform, you may assert your aforementioned rights vis-à-vis the relevant administrator free of charge at any time. Further information on asserting your rights is provided in section D below.

D.   Your contacts 

1. Contact persons for exercising your rights

The primary contact person for exercising your rights is the administrator of the relevant social media platform, who in each case alone can provide direct access to necessary information or the functionality of the respective platform and take appropriate action immediately. The contact persons for exercising your rights vis-à-vis the administrator of the relevant social media platform, as well as further information, can be found in the information on data protection on the following web pages of each social media platform:

  1. Instagram privacy policy at https://help.instagram.com/519522125107875,
  2. Facebook data policy at https://www.facebook.com/privacy/explanation,
  3. LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy,
  4. XING privacy policy at https://privacy.xing.com/de/datenschutzerklaerung, 
  5. Kununu privacy policy at https://privacy.xing.com/de/datenschutzerklaerung, and
  6. YouTube privacy policy at https://policies.google.com/privacy?hl=en. 

If support from PowerCo SE is possible or necessary, we will of course support you, for example, by forwarding your request to the administrator of the relevant social media platform so that you can exercise your rights vis-à-vis the administrator of the social media platform.

For questions regarding exercising your rights and further information, please contact birte.schmalfeldt-langenstein@volkswagen.de or datenschutz@powerco.de.

2. Data Protection Officer at PowerCo SE

Our data protection officer is your contact person for matters relating to data protection concerning PowerCo SE:

Data Protection Officer at PowerCo SE

Group Data Protection Volkswagen AG

Berliner Ring 2, 38440 Wolfsburg, Germany

Version dated: November 2023