Privacy Policy

1. Information concerning the collection, processing and use of personal data

We, Audi Business Innovation GmbH, are committed to protecting the personal data of users (‘you’) which we collect when you visit our website audiondemand.com and any sub-sites (‘Platform’).

Below you will find more information about what personal data we collect when you use the Platform and how and for what purposes we process it. Questions about data protection in relation to our Platform can be sent to our data protection officer using the contact details in section 2.2 unterhalb.

The German Data Protection Act (‘BDSG’) and German Telemedia Act (‘TMG’) or from 25 May 2018, the EU General Data Protection Regulation (‘GDPR’) govern how your personal data is collected, processed and used on our Platform.

 

2. General information

2.1 Data controller

The data controller for the processing of your personal data when using the Platform and arranging mobility services is

Audi Business Innovation GmbH
Hochbrückenstr. 6
80331 Munich, Germany

Email: info.businessinnovation@audi.de

 

2.2 Data protection officer

You can contact our data protection officer as follows:

Audi Business Innovation GmbH         
Data protection officer           
Hochbrückenstr. 6

80331 Munich, Germany

[data@audimobility.com]

 

3. Collection, processing and use of personal data

3.1 Personal data

Personal data means all information referring to a specific identified or identifiable natural person. This includes data such as your surname, name, Customer ID, telephone number, postal address and email address and all categories of data as mentioned below which you enter when registering on the Platform, book a mobility service, or otherwise make use of a service offered via our Platform.

 

3.2 Technical data that we collect and log when you access our servers the run the Platform

When you access the Platform, we collect the following information:

  • Date and time of platform retrieval
  • Name of file retrieved
  • Site from which the file was requested
  • Access status (file transferred, file not found, etc.)
  • Web browser used and operating system used
  • IP address
  • System language used

Information of this type is collected solely in anonymised form and processed by us so that the Platform is displayed better on your terminal device and so that based on the IP address and your geo-location derived from it, we can preselect the corresponding national website of the Platform, and in statistical form to help us improve the platform.

 

3.3 Registering on the Platform

If you wish to use arrangement services on our Platform, you must first register as a user. When you register, we collect your personal details such as your first name and last name, date of birth, home and business address if applicable, mobile phone number, email address and a password of your choice for your user account and your driving licence details (jointly ‘Registration Data’).

If you have not granted us your consent to the further use of your Registration Data, except for the uses we mention below, we will use this data exclusively for arranging mobility services with third-party providers in accordance with the User Agreement you enter into when registering with the Platform.

The legal basis for the collection and further processing of the Registration Data, apart from the password and driving licence details, is section 14 TMG, or from 25 May 2018, Article 6(1)(b) GDPR whereas the processing is necessary to perform the contract that you have entered into by registering on the Platform. For processing the password, the legal basis is set out in section 15(1) TMG or from 15 May 2018, Article 6(1)(b) GDPR and for processing the driving licence, in section 28(1) first sentence 1 no. 1 BDSG, or from 25 May 2018, Article 6(1)(b) GDPR.

 

3.4. Booking a mobility service

If you book a mobility service on the Platform, e.g. a vehicle, we also collect your credit card details which you entered for payment purposes, plus information about your booking such as details of the vehicle, place and time of collection and return (which we refer to in this policy as the  ‘Booking Information’).

We transmit your Booking Information for the purpose of our arrangement service to the provider of the mobility service you booked, to enable it to conclude the contract for your desired mobility service.  The provider of the mobility service will process your personal data in accordance with its privacy policy, which it shall make available to you, including on its website, at the time you make your booking.”

We also transmit your credit card details for the purposes of verifying the cardholder and checking the credit facility and for charging the fees due to our provider for the mobility service you use, to our payment services provider, Heidelberger Payment GmbH and HPC GmbH, both Vangerowstraße 18, 69115 Heidelberg, Germany, their cooperation partner PAY.ON AG, Grillparzerstr. 18, 81675 Munich, Germany, and the acquirer HUELLEMANN & STRAUSS ONLINESERVICES S.A., 1 pl. du Marché, 6755 Grevenmacher, Luxembourg.

The legal basis for this is section 28(1) first sentence 1 no. 1 BDSG, or from 25 May 2018, Article 6(1)(b) GDPR. i.e. the processing is necessary to perform a contract that you have entered into.

If you acquired your driving licence in the United Kingdom and intend to hire a vehicle in the United Kingdom, we will also transmit your driving licence details and information about the vehicle you have chosen to our service provider, DCML Limited, 1 Waterloo Court, Waterloo Road, Stockport, Cheshire, SK1 3DU, United Kingdom, which compares these details with those of the DVLA (Driver and Vehicle Licensing Agency) to verify your age details and the scope of permissions on your licence and to check whether you are entitled to drive the desired vehicle.

The legal basis for this processing is set out in section 28(1) first sentence 1 no. 1 BDSG, or from 25 May 2018, in Article 6(1)(b) GDPR i.e. the processing is necessary to perform a contract that you have entered into.

If you wish to hire a vehicle in the United Kingdom, we will also transmit your driving licence details and information about the vehicle you have chosen to our service provider, DCML Limited, 1 Waterloo Court, Waterloo Road, Stockport, Cheshire, SK1 3DU, United Kingdom, which will send these details to the insurance company Aviva plc, St Helen’s, 1 Undershaft, London EC3P 3DQ, United Kingdom (hereinafter ‘Aviva’) for the purpose of preparing the necessary insurance coverage for the desired vehicle, taking into account your age, the chosen vehicle and any other information accessible to it. In case Aviva should refuse to grant insurance coverage, upon your request we will explain you the reasons for this decision.

The legal basis for this processing is set out in section 28(1) first sentence 1 no. 1 BDSG, or from 25 May 2018, in Article 6(1)(b) GDPR i.e. the processing is necessary to perform a contract that you have entered into.

 

3.5 Booking history in your user account and central customer service

We also process your Registration Data and Booking Information and the invoices for your bookings given to us by the provider in performance of our User Agreement to make these and your booking history available to you in your user account on the Platform and for the purpose of handling your queries in the context of customer service. The legal basis for this processing is set out in section 28(1) first sentence 1 no. 1 BDSG, or from 25 May 2018, in Article 6(1)(b) GDPR i.e. the processing is necessary to perform a contract that you have entered into.

 

3.6 Cookies

Our Platform uses cookies. Cookies are text files containing information to identify repeat visitors solely for the duration of their visit to our internet sites. Cookies are saved on the hard disk or any other permanent memory of your terminal device. The cookies on our web pages do not contain any personal data whatsoever about you.

Cookies save you from having to enter data multiple times, make it easier for you to transmit certain content and help us identify especially popular areas of our online offering. This lets us tailor the content of our Platform more precisely to your needs.

If you wish, you can disable the cookies at any time via your browser settings. Please use your browser’s help function to find out how to change these settings.

The following cookies are used on the websites:

 

Provider: Adobe Analytics

Name: s_cc

Usage: The cookie determines wheter cookies are enabled in the user's browsers settings.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_dl

Usage: The cookie saves the number of days that have passed since thelast visit to the page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_sq

Usage: The cookie stores information about the links that were previously clicked by the user within the measured pages. This information is used to create a "ClickMap". A "ClickMap" is an overview within Adobe Analytics, which shows the entire clicks of the user on the page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_vi

Usage: The cookie is used to determine a unique user ("Unique Visitor"). For this, an information ID ("ID") and a time stamp ("Timestamp") are assigned. This allows Adobe Analytics to recognize a user during a recurring visit.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_fid

Usage: The cookie is used to determine a unique user ("Unique Visitor"). The cookie is a "fallback cookie" if the cookie "s_vi" is blocked, which is normally used for this purpose.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_depth

Usage: The cookie counts the number of pages the user has opened during his visit. Each time the user sees a new page, this number is increased by the value "1".

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_invisit

Usage: The cookie identifies whether the user visits the domain for the first time. The cookie states TRUE or FALSE.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_ppv

Usage: When a customer leaves the page, the cookie saves the percentage of the page viewed by the user. This is, for example, relevant for pages on which the customer can scroll down ("Percent per page viewed").

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_tbm

Usage: The cookie identifies the marketing channel through which the user came to the page. For example, paid ads on Google can be a marketing channel.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: s_vnum

Usage: The cookie saves the number of visits ("Visits") from a unique visitor ("Unique Visitor"). This is how you can measure how often a visitor has been on the site for 30 days.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_appvn

Usage: The cookie saves the number of visits ("visits") per application. Each application that is measured within Adobe Analytics gets a tracking name.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_cmdep

Usage: The cookie identifies the combination of marketing channel and campaign. For example, paid ads on Google can be a marketing channel. A campaign can be a banner ad from Audi on an external page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_pCmp

Usage: The cookie identifies the previous "Campaign Tracking Code". The "Campaign Tracking Code" is given, for example, when a customer clicks on a banner ad from Audi on an external page and has thus reached the Audi target page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_prevpage

Usage: The cookie identifies which page the user has visited ("previous page").

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_prop32

Usage: The cookie identifies the current application.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_tsev

Usage: The cookie allows or is the prerequisite so that the "visit duration" can be calculated with the cookie sc_tsv .

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_tsv

Usage: The cookie saves the duration of the visit to the site due to the information in the cookie sc_tsev.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_c68

Usage: The cookie assigns a "Custom Timestamp" for the visit. The date and time of the visit on the page are recorded. This can be used to track the order of the anonymous user's actions. The cookie is set once per visit to the page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_tsp

Usage: The cookie assigns the current time stamp ("Timestamp") for the visit of the customer. In contrast to the cookie sc_c68, this is given at the beginning of each individual page call, so that the duration of the visit can be measured on the page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_v0

Usage: The cookie saves the current campaign tracking code. A campaign is, for example, a click on a banner ad from Audi on an external page.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_v41

Usage: The cookie saves the marketing channels used by the user so far. For example, paid ads on Google can be a marketing channel.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_v43

Usage: The cookie stores the tracking codes of the campaigns that the user has previously called.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: sc_v49

Usage: The cookie stores the contents of the URL parameter "vanity". "Vanity" stands for a domain that is within Audi, but uses a domain other than uk.audiondemand.com.

Type: Performance-Cookie

 

Provider: Adobe Analytics

Name: TrackingOptOut

Usage: The cookie indicates whether a visitor has disabled tracking of Adobe Analytics.

Type: Performance-Cookie

 

3.7 Web tracking (measuring reach)

Your user experience on the Platform is important to us and so this Platform uses a web analysis tool (incl. Omniture Site Catalyst, Omniture Genesis, Omniture Discover, Omniture TagManager, Omniture SaintBernard) with Adobe that enables us to optimise our services to your needs. Adobe Analytics uses cookies to show your preferences when visiting our Platform. The information generated here (including the IP address) is allocated unique ID (i.e. a pseudonym) as standard procedure before being saved, so it is virtually impossible to connect it to you personally. The Platform has been adapted accordingly to guarantee anonymised recording of IP addresses (known as IP masking). Only after this anonymisation is an analysis done for reporting purposes. The information generated by these cookies is normally transmitted to an Adobe server within the European Union. However, it cannot be ruled out that in the event of a technical emergency, this data is transmitted to the US and stored there.

As a user of our websites, you of course have the option of blocking cookies at any time via your browser settings at any time (see section 3.6 above). You can object to any future recording of your user behaviour on the Platform; by clicking on the link below, you will find an instruction how to disable cookies on your computer: Disable tracking

The legal basis for this processing is set out in section 15(3) TMG or Article 6(1)(f) GDPR (processing necessary for the purposes of the legitimate interests pursued by any person except where overridden by your fundamental rights and freedoms). However, you have the right to object to this creation and storage of a usage profile under a pseudonym (section 15(3) first and second sentences TMG and from 25 May 2018, Article 21 GDPR). The legitimate interest in the meaning of Article 6(1)(f) GDPR that we pursue when processing the data described above is our interest in both (i) producing customer information and offers from the automotive sector and car-related services of Audi, Audi Business Innovation GmbH and cooperation partners, such as service and product information (e.g. new fleet vehicles, offers regarding suitable vehicles within the Audi mobility services or suitable pre-owned car offers as well as vehicle features such as Functions on Demand or Connect), news (e.g. newly opened Audi mobility services locations), promotions and special offers (e.g. rebate promotions, discounts, cooperation offers) as well as surveys on customer satisfaction and customer support, and (ii) improving user experience of our Platform.

4. Marketing

If you have given us your consent to this and/or if the statutory requirements are met, we will use your personal data provided during registration described under section 3.3 oben and your information described above under section 3.4 about the booking of a vehicle in order to produce and send you personally tailored customer information and offers from the automotive field and car-related services from Audi, Audi Mobility and cooperation partners as well as service and product information (e.g. new fleet cars, offers for suitable vehicles within the Audi mobility services or suitable pre-owned car offers and features of vehicles such as Functions on demand or Connect), news (e.g. new openings of Audi mobility service locations), promotions and special offers (e.g. cashback promotions, discounts, offers).

 

5. Your rights as a data subject

Under BDSG and, from 25 May 2018, under GDPR, you as a data subject have various rights in respect of your personal data and our processing of those data as the data controller. To assert such data subject rights, please contact our data protection officer (see above, section 2.2). Please note that our data protection officer may ask you to identify yourself as the data subject (e.g. by presenting a copy of your ID); if such data subject rights are asserted, we must make sure that these rights are really being asserted by the data subjects themselves to avoid misuse by third parties to the detriment of the actual data subject.

 

5.1 Right to information

Under section 34 BDSG, the data subject has the right to information about the personal data relating to it and

a) the purpose of processing;

(b) the categories of personal data processed; and

(c) the recipients or categories of recipients to which the personal data has been disclosed or will be disclosed, especially in the case of recipients in third countries or in international organisations;

and from 25 May 2018 according to Article 15 GDPR, also about

(d) the planned period for which the personal data will be stored (if possible), or if not possible, the criteria for defining this period;

(e) if the personal data is not collected from the data subject, all available information about the origin of the data; plus

(f) the other data subject rights explained below.

 

5.2 Right to correction

Under section 35(1) BDSG, incorrect personal data must be corrected by the data controller. From 25 May 2018, the user as a data subject under data protection law also has a right to request correction by the data controller of incorrect personal data relating to it and the completion of incomplete personal data without delay.

 

5.3 Right to deletion or restriction of processing

Under section 35(2) BDSG, the data controller is obliged to delete personal data and from 25 May 2018 the data subject has a right to this if the standard preconditions in section 35(2) BDSG and/or Article 17(1) GDPR are in place and none of the exclusion grounds listed in section 35(2) BDSG/Article 17(3) GDPR exist. From 25 May 2018, the data subject has a right to be forgotten in the circumstances set out in Article 17(2) GDPR if we as data controllers previously disclosed the personal data of a data subject publicly, but are required to delete it according to Article 17(1) GDPR.

 

5.4 Right of objection

Where the legal basis on which we rely for processing your personal data is subject to the criteria for the balancing of interests in section 28(1) first sentence 1 no. 2 BDSG, and/or Article 6(1)(f) GDPR, from 25 May 2018 you will have the right under Article 21 GDPR to object to it. If you do so, we will review our balancing of interests once again. Please send your objection to the address of our data protection officer given in section 2.2 You also have the right at any time to object to the use of your personal data for direct marketing purposes by sending an email to us at the address of our data protection officer given under section 2.2 or the link provided in our email without incurring any costs other than what you may pay to have a connection to the internet. In this case we will stop further use of your data for the purposes of advertising. 

 

5.5 Right of data portability

Pursuant to Article 6(1) GDPR and without prejudice to your right to data erasure pursuant to Article 17 GDPR (cf. section 5.3 above), you shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where our processing is based on your prior consent. You have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

 

5.6 Right of complaint to the supervisory authority

From 25 May 2018, under Article 77 of the GDPR you have a right to complain to the supervisory authority if they believe that the processing of their personal data is taking place unlawfully. The competent supervisory authority for us is the

Bayerisches Landesamt für Datenschutzaufsicht
Bavarian Data Protection Supervisory Authority)

 

Postal address:

Postfach 606

91511 Ansbach

Germany

 

Street Adress:

Promenade 27 (Schloss)
91522 Ansbach
Germany


Telephone: +49 (0) 981 53 1300
Fax: +49 (0) 981 53 98 1300
Email: poststelle@lda.bayern.de

 

6. Duration of storage

Under applicable data protection laws, we are obliged to ensure that the duration of our storage of personal data is limited to what is strictly necessary. According to section 35(2) no. 3 BDSG or Article 17(1) GDPR, personal data processed for particular purposes which is no longer necessary for the purpose of the storage must be deleted or anonymised. We will therefore delete your data after you de-register from the platform and after expiry of the subsequent limitation and statutory retention periods. These statutory retention periods arise in particular from the commercial law provisions (especially section 257 German Commercial Code) for commercial letters received and reproduction of sent commercial letters, which also cover corresponding emails (6 years from the date of de-registration) and the tax law provisions (especially section 147 German Tax Code) for all accounting-related documents (6 to 10 years from the date of de-registration).

 

7. Transmission to third countries

On our behalf, Adobe can use the information in Adobe Analytics and transfer information generated about your use of the Platform to an Adobe server in the USA and store it there (see section 3.7). Adobe Systems Incorporated has committed to complying with the EU-US Privacy Shield and obtain the according certification. The European Commission, by decision of 12 July 2016 (document C(2016) 4176), has ruled that the US offers a reasonable level of protection for personal data, which can be transmitted from the European Union to organisations in the United States that are currently registered with the EU-US Privacy Shield scheme.

 

8. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Updates to this Privacy Policy will be published on our Platform. Amendments are valid as of publication on our Platform. We therefore advise you to visit this site regularly to inform yourself of any updates which have been made.
 

Last updated: 30 August 2017