Administrator of the Personal Data

With respect to point 1: Establishing contact with the Dealer

How we process your data? The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR)

1) Scope of data identification, contact and mailing details, vehicle data, including VIN, enquiry details (also on our website) – depending on what data you decided to provide to the Authorised Dealer/Authorised Service Partner;

2) Joint Controllers and the purposes of and legal grounds for processing:

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Authorised Dealer/Authorised Service Partner;

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

For what purpose and on what legal ground:

Due to your contacting or being contacted by the Authorised Dealer/Authorised Service Partner or VGP (e.g. visiting a showroom and providing your details, handing your card, contacting the showroom's call centre, sending an e-mail) and enquiring about a test drive or the details of an offer to purchase a Volkswagen Commercial Vehicles brand vehicle or other automotive products, accessories or services related to the brand, we will use the contact details provided by you to confirm your interest, present you with Volkswagen Commercial Vehicles brand product/service information or arrange a test drive that you are interested in, using the phone number or e-mail address (where provided by you), based on your consent expressed by providing your details. We will call you back or write you an e-mail, and if you confirm your continued interest, we will continue to process your enquiry. In this respect, the provision of such data is voluntary, but necessary for contact, the preparation of an offer or the arrangement of a test drive.

If you leave your phone number or e-mail address, we consider that you consent to be contacted in connection with your enquiry, in accordance with the e-marketing laws and regulations. Preparation of a specific offer at your request will take place on the basis of steps taken to enter into a contract, and a test drive on the basis of a contract, unless you contact us as an employee or contact person on behalf of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis in connection with the enquiry;

For the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR), we will use your data to:

• survey the quality of service within the dealership network;
• for archiving (evidence) purposes in order to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims;
• for analytical and statistical purposes, improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base;
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities;
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services;
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked ”IOD”. You may also directly contact the other Controllers.

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the Call Centre, auditors, advisors. The data recipients may be Group companies, including [the Head Office], the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o.;

5) Data storage period: We will process your personal data in connection with your interest in a test drive or offer for the period necessary to handle your enquiry (not longer than six months if you lose interest in the offer or test drive). In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years, unless it is necessary to store such data for a longer period under the applicable provisions of law, or if it is necessary for the establishment, exercise or defence of legal claims;

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent to being contacted by phone or electronically at any time at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl, by contacting VGP or VGP's DPO in writing (contact details above), or by directly contacting the Authorised Dealer/Authorised Service Partner. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates personal data protection laws and regulations;

9) Source of origin of the data Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

With respect to point 2: Remaining in business relations

How we process your data? The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR)

1) Who the Controller of your data is:

a) to the extent of actions taken to perform a future contract (handling of enquiries, preparation of offers) – as Joint Controllers:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• the Authorised Dealer/Authorised Service Partner of the Volkswagen Commercial Vehicles brand, selected by the company for which you work – the current list and contact details can be found on the Volkswagen Commercial Vehicles website and at Authorised Dealers and Authorised Service Partners);

b) in connection with an order for or purchase of a vehicle – as Joint Controllers:

• VGP;
• Authorised Dealer/Authorised Service Partner;
• Volkswagen Commercial Vehicles (Head Office);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

2) Scope of data꞉ identification and business contact details.

3) For what purpose and on what legal ground:

Due to the fact that there is a business relationship between VGP or the Head Office and your employer, the Joint Controllers process your personal data as the contact person of their customer for the purposes of their legitimate interests (legal basis: Article 6(1)(f) of the GDPR).

We will process your data in order to maintain on-going contact with the customer you represent, in the first instance to invite the customer to request offers, handle enquiries, prepare offers, perform concluded contracts. In this respect, the provision of such data is voluntary, but necessary for on-going business contact.

A request for contact from VGP or the Authorised Dealer/Authorised Service Partner, expressed in the first instance by leaving a contact phone number or e-mail (business details) by you or your employer (or an entity acting on your employer's behalf), will be considered by us to be a consent to on-going business contact with the customer, in accordance with the e-marketing laws and regulations.

For the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR), we will also use your data꞉

• in order to survey the quality of service within the dealership network;
• for archiving (evidence) purposes in order to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims;
• for analytical and statistical purposes, improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base;
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities;
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services;
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data.

4) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”.

5) Data recipients: Companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the Call Centre, auditors, advisors. The data recipients may be Group companies, including Volkswagen AG and Authorised Dealers/Authorised Service Partners, the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o.;

6) Data storage period: We will store your personal data for as long as we have a business relationship with your employer or until you object to storing them or cease to act as a contact person for the customer;

7) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent to being contacted by phone or electronically at any time at the Authorised Dealer or Authorised Service Partner. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl or by contacting VGP or VGP's DPO in writing (contact details above). You may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

8) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

9) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates personal data protection laws and regulations;

10) Source of origin of the data꞉ Data made available by you or the entity represented by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

11) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

With respect to point 3: Ordering or purchasing a vehicle

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites), details of orders and executed contracts, VIN, vehicle and vehicle-generated data, vehicle history, location data, complaint data, financial data (bank account number and product financing details). In the case of special discount offers, also other additional information confirming the eligibility for the discount, e.g. details of employment, occupation, function;

2) Joint Controllers and the purposes of and legal grounds for processing:

In connection with an order for or purchase of a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Head Office: Volkswagen Commercial Vehicles
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• for the performance of a contract or in order to take steps prior to entering into a contract (legal basis: Article 6(1)(b) of the GDPR);
• for the performance of and on the basis of provided warranty (legal basis: Article 6(1)(b) of the GDPR);
• in order to handle warranty claims, complaints, handling and settling reported damage, technical defects (legal basis: Article 6(1)(b) of the GDPR);
• if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• for the purposes of safety recalls and discharge of product safety obligations, as this is necessary for compliance with a legal obligation and protection of your vital interests or those of another person (legal basis: Article 6(1)(c) and (d) of the GDPR);
• in order to provide after-sales service consisting in maintaining the relationship related to the use of a Volkswagen Commercial Vehicles brand vehicle, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR)
• in order to survey the quality of service within the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base, financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors. The data recipients may be Group companies, including Volkswagen AG and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, the entities providing financing or insurance services;

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be stored by us for the period in which claims related to the contract may emerge, i.e. for 12 years plus one year after the end of the year in which the contract is completed, where 12 years is the longest possible period for the bringing of warranty claims, and the additional year is for last-minute claims, delivery problems; the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In the case of special service campaigns, we may process your personal data for the aforementioned period of ten years after the end of the year in which the contract is completed. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for ten years.

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability). You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims);

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

With respect to point 4: Ordering or purchasing a vehicle and giving consent for marketing purposes

How we process your data? The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR).

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites), details of orders and executed contracts, VIN, vehicle and vehicle-generated data, vehicle history, location data, complaint data, financial data (bank account number and product financing details). In the case of special discount offers, also other additional information confirming the eligibility for the discount, e.g. details of employment, occupation, function;

2) Joint Controllers and the purposes of and legal grounds for processing (depending on the purpose of processing, the controllers of your personal data are):

a) In connection with an order for or purchase of a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Head Office: Volkswagen Commercial Vehicles
• Authorised Dealer/Authorised Service Partner; 

For what purpose and on what legal ground:

• for the performance of a contract or in order to take steps prior to entering into a contract (legal basis: Article 6(1)(b) of the GDPR);
• for the performance of and on the basis of provided warranty (legal basis: Article 6(1)(b) of the GDPR);
• in order to handle warranty claims, complaints, handling and settling reported damage, technical defects (legal basis: Article 6(1)(b) of the GDPR);
• if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• for the purposes of safety recalls and discharge of product safety obligations, as this is necessary for compliance with a legal obligation and protection of your vital interests or those of another person (legal basis: Article 6(1)(c) and (d) of the GDPR);
• in order to provide after-sales service consisting in maintaining the relationship related to the use of a Volkswagen Commercial Vehicles brand vehicle, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR)
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base (for creating individual profiles, see point b) below), financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

b) And additionally, in connection with the consent for marketing purposes (the provision of data is voluntary):

Who: VGP and Head Office;

For what purpose and on what legal ground:

• for the purpose of offering you Volkswagen Commercial Vehicles brand products and services and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand (marketing) (legal basis: Article 6(1)(a) of the GDPR);
• for the purpose of selecting offers of Volkswagen Commercial Vehicles brand products and services, and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand, according to your needs, interest, profile – i.e. for the purpose of profiling, including the use of automated processes, consisting in compiling your data, within the scope of your consent, from various sources (including data collected by VGP, the Authorised Dealer or Authorised Service Partner, the websites) and the profile attributed to you on this basis, resulting in the selection and presentation of advertisements or offers corresponding to your profile to you. If, in any respect, an advertisement or offer intended for you does not correspond to your needs or interests, or we should take other factors into account, please contact us (legal basis: Article 6(1)(a) of the GDPR);
• in order to carry out after-sales activities consisting in analysing and surveying customer satisfaction, interest in the Volkswagen Commercial Vehicles brand and Volkswagen Commercial Vehicles brand products and services (legal basis: Article 6(1)(a) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes, for internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors, and, for marketing purposes, also Authorised Dealers and Authorised Service Partners of the Volkswagen Commercial Vehicles brand, whose current list and contact details can be found on the Volkswagen Commercial Vehicles website and at the Authorised Dealers and Authorised Service Partners. The data recipients may be Group companies, including Volkswagen AG and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o. (if there is a legal basis for that);

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be processed by us for the period in which claims related to the contract may emerge, i.e. for 12 years plus one year after the end of the year in which the contract is completed, where 12 years is the longest possible period for the bringing of warranty claims, and the additional year is for last-minute claims, delivery problems; the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In the case of special service campaigns, we may process your personal data for the aforementioned period of ten years after the end of the year in which the contract is completed. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for ten years. Your personal data will be processed for marketing purposes for the period for which these purposes based on consent remain valid, but not longer than for five years after the last contact with you, and if you withdraw your consent, until your consent is withdrawn. Moreover, we will keep evidence of your consent for evidential purposes, i.e. to prove the facts in case of any claims related to the processing of personal data, until the statute of limitations expires;

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent using the form on www.vw-group.pl/pl/prywatnosc or at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

With respect to point 5: Requesting a service and purchasing parts and accessories

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites), details of orders and executed contracts, VIN, vehicle and vehicle-generated data, vehicle history, location data, complaint data, financial data (bank account number and product financing details);

2) Joint Controllers and the purposes of and legal grounds for processing

In connection with requesting a service and purchasing parts and accessories of the Volkswagen Commercial Vehicles brand (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Head Office: Volkswagen Commercial Vehicles
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• for the performance of a contract (legal basis: Article 6(1)(b) of the GDPR);
• in order to handle warranty claims, complaints, handling and settling reported damage, technical defects (legal basis: Article 6(1)(b) of the GDPR);
• if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• in order to provide after-sales service consisting in maintaining the relationship related to the use of a vehicle, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR)
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base, financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors. The data recipients may be Group companies, including Volkswagen AG and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services;

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be stored by us for the period in which claims related to the contract may emerge, i.e. for ten years plus one year after the end of the year in which the contract is completed; the additional year is for last-minute claims, delivery problems, and the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for ten years. 

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability). You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims);

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.    

With respect to point 6: Requesting a service, purchasing parts and accessories, and giving consent for marketing purposes

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites), details of orders and executed contracts, VIN, vehicle and vehicle-generated data, vehicle history, location data, complaint data, financial data (bank account number and product financing details).

2) Joint Controllers and the purposes of and legal grounds for processing (depending on the purpose of processing, the controllers of your personal data are):

a) in connection with requesting a service or purchasing parts and accessories of the Volkswagen Commercial Vehicles brand (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Head Office: Volkswagen Commercial Vehicles
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• for the performance of a contract (legal basis: Article 6(1)(b) of the GDPR);
• in order to handle warranty claims, complaints, handling and settling reported damage, technical defects (legal basis: Article 6(1)(b) of the GDPR);
• if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• for the purposes of safety recalls and discharge of product safety obligations, as this is necessary for compliance with a legal obligation and protection of your vital interests or those of another person (legal basis: Article 6(1)(c) and (d) of the GDPR);
• in order to provide after-sales service consisting in maintaining the relationship related to the use of a vehicle, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR)
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base (for creating individual profiles, see point b) below), financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

b) and additionally, in connection with the consent for marketing purposes (the provision of data is voluntary):

Who:

• VGP and Head Office;

For what purpose and on what legal ground:

• for the purpose of offering you Volkswagen Commercial Vehicles brand products and services and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand (marketing) (legal basis: Article 6(1)(a) of the GDPR);
• for the purpose of selecting offers of Volkswagen Commercial Vehicles brand products and services, and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand, according to your needs, interest, profile – i.e. for the purpose of profiling, including the use of automated processes, consisting in compiling your data, within the scope of your consent, from various sources (including data collected by VGP, the Authorised Dealer or Authorised Service Partner, the websites) and the profile attributed to you on this basis, resulting in the selection and presentation of advertisements or offers corresponding to your profile to you. If, in any respect, an advertisement or offer intended for you does not correspond to your needs or interests, or we should take other factors into account, please contact us (legal basis: Article 6(1)(a) of the GDPR);
• in order to carry out after-sales activities consisting in analysing and surveying customer satisfaction, interest in the Volkswagen Commercial Vehicles brand and Volkswagen Commercial Vehicles brand products and services (legal basis: Article 6(1)(a) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes, for internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors, and, for marketing purposes, also Authorised Dealers and Authorised Service Partners of the Volkswagen Commercial Vehicles brand, whose current list and contact details can be found on the Volkswagen Commercial Vehicles website and at the Authorised Dealers and Authorised Service Partners. The data recipients may also be Group companies, including Volkswagen AG, and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o. (if there is a legal basis for that);

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be stored by us for the period in which claims related to the contract may emerge, i.e. for ten years plus one year after the end of the year in which the contract is completed; the additional year is for last-minute claims, delivery problems, and the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In the case of special service campaigns, we may process your personal data for the aforementioned period of ten years after the end of the year in which the contract is completed. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for ten years. Your personal data will be processed for marketing purposes for the period for which these purposes based on consent remain valid, but not longer than for five years after the last contact with you, and if you withdraw your consent, until your consent is withdrawn. Moreover, we will keep evidence of your consent for evidential purposes, i.e. to prove the facts in case of any claims related to the processing of personal data, until the statute of limitations expires;

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent using the form on www.vw-group.pl/pl/prywatnosc or at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

With respect to point 7: Showing interest in a vehicle purchase offer

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites); and if you are our customer, also data collected about you as part of our relationship to date.
In the case of special discount offers, also other additional information confirming the eligibility for the discount, e.g. details of employment, occupation, function;

2) Joint Controllers and the purposes of and legal grounds for processing:

In connection with your interest in an offer for the purchase of a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for taking steps in order to perform a future contract):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• in order to take steps necessary for the performance of a contract, i.e. the preparation and presentation of an offer at your request (legal basis: Article 6(1)(b) of the GDPR), and if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• with regard to telephone or e-mail contact regarding a requested offer, we consider the fact that you have left these data as your consent to contact you for this purpose in accordance with the e-marketing laws and regulations;
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base, financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR;for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors. The data recipients may be Group companies, including [the brand's Head Office], and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services;

5) Data storage period: We will process your personal data in connection with your interest in and preparation of an offer for the period necessary to handle your offer enquiry (not longer than six months if you lose interest in the offer or, if you withdraw your consent earlier, until its withdrawal) and for the period necessary to enter into a contract. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years.

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent to being contacted by phone or electronically at any time at the Authorised Dealer or Authorised Service Partner; withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO. 

With respect to point 8: Showing interest in a vehicle purchase offer and giving consent for marketing purposes

How we process your data? (The information obligation under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR)).

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, offer or enquiry details (also on our websites); and if you are our customer, also data collected about you as part of our relationship to date. In the case of special discount offers, also other additional information confirming the eligibility for the discount, e.g. details of employment, occupation, function;

2) Joint Controllers and the purposes of and legal grounds for processing (depending on the purpose of processing, the controllers of your personal data are):

a) in connection with your interest in an offer for the purchase of a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for taking steps in order to perform a future contract):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• in order to take steps necessary for the performance of a contract, i.e. the preparation and presentation of an offer at your request (legal basis: Article 6(1)(b) of the GDPR), and if you are an employee or a contact person of a customer – then your personal data will be processed for the purposes of our legitimate interests consisting in the ability to contact you on an ongoing basis (legal basis: Article 6(1)(f) of the GDPR);
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base (for creating individual profiles, see point b) below), financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR;
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

b) and additionally, in connection with the consent for marketing purposes (the provision of data is voluntary):

Who: VGP and Head Office: Volkswagen Commercial Vehicles;

For what purpose and on what legal ground:

• for the purpose of offering you Volkswagen Commercial Vehicles brand products and services and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand (marketing) (legal basis: Article 6(1)(a) of the GDPR);
• for the purpose of selecting offers of Volkswagen Commercial Vehicles brand products and services, and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand, according to your needs, interest, profile – i.e. for the purpose of profiling, including the use of automated processes, consisting in compiling your data, within the scope of your consent, from various sources (including data collected by VGP, the Authorised Dealer or Authorised Service Partner, the websites) and the profile attributed to you on this basis, resulting in the selection and presentation of advertisements or offers corresponding to your profile to you. If, in any respect, an advertisement or offer intended for you does not correspond to your needs or interests, or we should take other factors into account, please contact us (legal basis: Article 6(1)(a) of the GDPR);
• in order to carry out after-sales activities consisting in analysing and surveying customer satisfaction, interest in the Volkswagen Commercial Vehicles brand and Volkswagen Commercial Vehicles brand products and services (legal basis: Article 6(1)(a) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes, for internal settlements between the Importer, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors, and, for marketing purposes, also Authorised Dealers and Authorised Service Partners of the Volkswagen Commercial Vehicles brand, whose current list and contact details can be found on the Volkswagen Commercial Vehicles website and at the Authorised Dealers and Authorised Service Partners. The data recipients may be Group companies, including [the Head Office], the Authorised Dealer and Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o. (if there is a legal basis for that);

5) Data storage period: We will process your personal data in connection with your interest in and preparation of an offer for the period necessary to handle your offer enquiry (not longer than six months if you lose interest in the offer or, if you withdraw your consent earlier, until its withdrawal) and for the period necessary to enter into a contract. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years. Your personal data will be processed for marketing purposes for the period for which these purposes based on consent remain valid, but not longer than for five years after the last contact with you, and if you withdraw your consent, until your consent is withdrawn. Moreover, we will keep evidence of your consent for evidential purposes, i.e. to prove the facts in case of any claims related to the processing of personal data, until the statute of limitations expires;

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent using the form on www.vw-group.pl/pl/prywatnosc or at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO. 

With respect to point 9: Test drive and providing a vehicle

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, driving licence number, tested vehicle details, your enquiry details (also on our websites);

2) Joint Controllers and the purposes of and legal grounds for processing

In connection with a test drive and providing a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• for the provision of a test drive service (legal basis: Article 6(1)(b) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base, financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors. The data recipients may be Group companies, including [the Head Office], the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, the entities providing financing or insurance services;

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be stored by us for the period in which claims related to the contract may emerge, i.e. for six years plus one year after the end of the year in which the contract is completed; the additional year is for last-minute claims, delivery problems, and the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years.

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability). You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims);

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO. 

With respect to point 10: Test drive and providing a vehicle, and giving consent for marketing purposes

How we process your data (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, driving licence number, tested vehicle's details, your enquiry details (also on our websites); and if you are our customer, also data collected about you as part of our relationship to date.

2) Joint Controllers and the purposes of and legal grounds for processing (depending on the purpose of processing, the controllers of your personal data are):

a) in connection with a test drive and providing a Volkswagen Commercial Vehicles brand vehicle (in this respect, your provision of such data is necessary for the performance of the contract, and their absence will prevent its performance):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Authorised Dealer/Authorised Service Partner;

For what purpose and on what legal ground:

• for the provision of a test drive service (legal basis: Article 6(1)(b) of the GDPR);
• in order to document the service provided, on the basis of tax, customs and accounting legislation (legal basis: Article 6(1)(c) of the GDPR);
• in order to survey the quality of service within the dealership network, for the purposes of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes – improved tailoring of products and services to the needs of our customers, general optimisation of our products, optimisation of service processes, building a customer knowledge base, financial analysis of VGP and the dealership network, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal sales network reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of managing the sales and customer service process, setting standards of customer service for the Volkswagen Commercial Vehicles brand, assuring the quality of products and services, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

b) and additionally, in connection with the consent for marketing purposes (the provision of data is voluntary):

Who:

• VGP and Head Office: Volkswagen Commercial Vehicles;

For what purpose and on what legal ground:

• for the purpose of offering you Volkswagen Commercial Vehicles brand products and services and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand (marketing) (legal basis: Article 6(1)(a) of the GDPR);
• for the purpose of selecting offers of Volkswagen Commercial Vehicles brand products and services, and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand, according to your needs, interest, profile – i.e. for the purpose of profiling, including the use of automated processes, consisting in compiling your data, within the scope of your consent, from various sources (including data collected by VGP, the Authorised Dealer or Authorised Service Partner, the websites) and the profile attributed to you on this basis, resulting in the selection and presentation of advertisements or offers corresponding to your profile to you. If, in any respect, an advertisement or offer intended for you does not correspond to your needs or interests, or we should take other factors into account, please contact us (legal basis: Article 6(1)(a) of the GDPR);
• in order to carry out after-sales activities consisting in analysing and surveying customer satisfaction, interest in the Volkswagen Commercial Vehicles brand and Volkswagen Commercial Vehicles brand products and services (legal basis: Article 6(1)(a) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes, for internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors, and, for marketing purposes, also Authorised Dealers and Authorised Service Partners of the Volkswagen Commercial Vehicles brand, whose current list and contact details can be found on the Volkswagen Commercial Vehicles website and at the Authorised Dealers and Authorised Service Partners. The data recipients may be Group companies, including [the Head Office], and the Authorised Dealer/Authorised Service Partner, Authorised Dealers/Authorised Service Partners of VGP, and the entities providing financing or insurance services, including Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o. (if there is a legal basis for that);

5) Data storage period: Your personal data processed in connection with and on the basis of a contract will be stored by us for the period in which claims related to the contract may emerge, i.e. for six years plus one year after the end of the year in which the contract is completed; the additional year is for last-minute claims, delivery problems, and the fact that the period runs from the end of the year is intended to set a single date for data removal in respect of contracts terminating in the given year. In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years. Your personal data will be processed for marketing purposes for the period for which these purposes based on consent remain valid, but not longer than for five years after the last contact with you, and if you withdraw your consent, until your consent is withdrawn. Moreover, we will keep evidence of your consent for evidential purposes, i.e. to prove the facts in case of any claims related to the processing of personal data, until the statute of limitations expires;

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent using the form on www.vw-group.pl/pl/prywatnosc or at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers. VGP and the Authorised Dealer/Authorised Service Partner will each be responsible for the implementation of data subjects' rights in their own processes or in their own IT systems;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.

How we process your data? (The information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (henceforth: GDPR))

1) Scope of data꞉ We process the following categories of your data꞉ identification, contact and mailing details, and if you are our customer, also offer or enquiry details (also on our websites), details of orders and executed contracts, VIN, vehicle and vehicle-generated data, vehicle history, location data, complaint data, financial data (bank account number and product financing details);

2) Joint Controllers and the purposes of and legal grounds for processing

In connection with the consent for marketing purposes (the provision of data is voluntary):

Who:

• Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, entered in the Business Register kept by the District Court in Poznań – Nowe Miasto and Wilda, 8th Business Division, under KRS number 0000327143, NIP Tax ID: 782-24-63-563, REGON Statistical ID: 301062169 (VGP);
• Head Office: Volkswagen Commercial Vehicles

For what purpose and on what legal ground:

• for the purpose of offering you Volkswagen Commercial Vehicles brand products and services and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand (marketing) (legal basis: Article 6(1)(a) of the GDPR);
• for the purpose of selecting offers of Volkswagen Commercial Vehicles brand products and services, and automotive accessories, products and services related to the Volkswagen Commercial Vehicles brand, according to your needs, interest, profile – i.e. for the purpose of profiling, including the use of automated processes, consisting in compiling your data, within the scope of your consent, from various sources (including data collected by VGP, the Authorised Dealer or Authorised Service Partner, the websites) and the profile attributed to you on this basis, resulting in the selection and presentation of advertisements or offers corresponding to your profile to you. If, in any respect, an advertisement or offer intended for you does not correspond to your needs or interests, or we should take other factors into account, please contact us (legal basis: Article 6(1)(a) of the GDPR);
• in order to carry out after-sales activities consisting in analysing and surveying customer satisfaction, interest in the Volkswagen Commercial Vehicles brand and Volkswagen Commercial Vehicles brand products and services (legal basis: Article 6(1)(a) of the GDPR);
• for archiving (evidence) purposes in the pursuit of our legitimate interests, i.e. to preserve information in the event of a legal need to prove facts, or potentially establish, exercise or defend legal claims (legal basis: Article 6(1)(f) of the GDPR);
• for analytical and statistical purposes, for internal settlements between VGP, the Head Office and the Authorised Dealer/Authorised Service Partner, as well as internal audits, internal reporting, verification of Authorised Dealer/Authorised Service Partner activities, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR);
• for the purpose of maintaining a central customer database, including prospective customers, combining data from different systems and sources, including the exercise of your rights, e.g. for updating your data, in the pursuit of our legitimate interests (legal basis: Article 6(1)(f) of the GDPR)

The joint controlling results from the pursuance by the above entities of objectives in the area of shared processes or shared IT systems within the sales network of Volkswagen Commercial Vehicles brand products.

3) Contact with VGP's Data Protection Officer: You may contact VGP's DPO by e-mail at: iod@vw-group.pl or in writing at the address of Volkswagen Group Polska sp. z o.o. with its registered office in Poznań (61-037), ul. Krańcowa 44, marked “IOD”; you may also directly contact the other Controllers;

4) Data recipients: The recipients of your personal data will be: companies providing services at our request, to which we will outsource activities involving data processing, in the first instance in the area of IT services, marketing services (including marketing agencies), market research, companies supporting the organisation and management of events, the call centre, auditors, advisors, and, for marketing purposes, also Authorised Dealers and Authorised Service Partners of the Volkswagen Commercial Vehicles brand, whose current list and contact details can be found on the Volkswagen Commercial Vehicles website and at the Authorised Dealers and Authorised Service Partners. The data recipients may be Group companies, including [the Head Office] and Volkswagen Bank GmbH Sp. z o.o. Poland Branch, Volkswagen Leasing GmbH Sp. z o.o. Poland Branch, Volkswagen Serwis Ubezpieczeniowy Sp. z o.o. (if there is a legal basis for that);

5) Data storage period: Your personal data will be processed for marketing purposes for the period for which these purposes based on consent remain valid, but not longer than for five years after the last contact with you, and if you withdraw your consent, until your consent is withdrawn. Moreover, we will keep evidence of your consent for evidential purposes, i.e. to prove the facts in case of any claims related to the processing of personal data, until the statute of limitations expires; In respect of any other purposes of our legitimate interests – for the period of validity of such purposes or until you object, in either case not longer than for five years.

6) Data subject's rights clause: You have the right to access your data, the right to rectify and erase your data, the right to restrict processing of your data, the right to transfer your data (data portability), the right to withdraw your consent using the form on www.vw-group.pl/pl/prywatnosc or at an Authorised Dealer or Authorised Service Partner of the Volkswagen Commercial Vehicles brand; withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. You may also exercise your rights by contacting us by email at: daneosobowe@vw-group.pl; you may also directly contact the other Controllers;

7) Right to object: You have the right to object to the processing of your data for the purposes of our legitimate interests, as defined above (in such case, we will cease to process your data for the above purposes unless we are able to demonstrate that compelling legitimate grounds exist for the processing of such data by us that override your interests, rights and freedoms, or that the data is necessary for the potential establishment, exercise or defence of legal claims). You have the right to object to direct marketing, including profiling;

8) Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority – in Poland, with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), if you believe that the processing of your personal data violates the GDPR;

9) Source of origin of the data꞉ Data made available by you, data collected and made available by or on behalf of the Controllers (mailing details as above), Authorised Dealers/Authorised Service Partners of VGP, data derived from documents, data derived from the websites; for businesses, also from public CEIDG and KRS registers;

10) If, in the course of processing, your personal data are transferred to recipients in third countries (outside the EEA), such transfer may take place on the basis of a decision that the third country ensures an adequate level of data protection taken by the European Commission or on the basis of standard data protection clauses adopted by the European Commission or on the basis of your explicit consent. For further information in this respect, please contact VGP's DPO.