Privacy Policy of the Audi MediaCenter / press and public relations work

AUDI AG would like to welcome you to the Audi MediaCenter.

In this Data Protection Notice (Privacy Policy) according to Article 13, 14 GDPR we are informing you about the processing of your personal data by Audi AG, Auto-Union-Straße 1, 85045 Ingolstadt ("we") in connection with the Audi MediaCenter and the public relations work of AUDI AG, as well as in the context of your work as a journalist, photographer, influencer or other multiplier.

However, the Audi MediaCenter website may contain links to external websites that are not covered by this privacy policy. The respective provider is responsible for processing personal data on these external sites. Please consult the provider regarding how your personal data are processed in connection with using external sites.

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing means any operation or set of operations performed with or without the aid of automated processes in connection with personal data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1. Who is responsible for data processing and whom can I contact?

The entity responsible for the processing of your personal data (the controller) is:

AUDI AG, Auto-Union-Straße 1, 85045 Ingolstadt.

If you have concerns about data protection, you can also contact our company's data protection officer:

AUDI AG Datenschutzbeauftragter, Auto-Union-Straße 1, 85045 Ingolstadt

E-Mail: datenschutz@audi.de

If you wish to assert your data protection rights, please adress them to

https://gdpr.audi.com

There you will find further information on how to assert your data protection rights.

If you have any general questions about this data protection notice or the processing of your personal date by AUDI AG, please use the following contact options:

E-Mail: info@audi-mediacenter.com

2. What data do we process and what sources do such data come from?

2.1 Access to the website

In general you can use the website for login without providing any personal data. However, registration for the event requires the entry of personal data (see section 2.2).

Each time you access the website, your Internet browser automatically transmits certain information, which we store in so-called “log files”.

In particular, the following information are transmitted automatically:

    • IP address (Internet Protocol address) of the terminal from which the online service is accessed;
    • Internet address of the website from which the online service was accessed (the so-called “source URL” or “referrer URL”);
    • Name of the service provider used to access the online offer;
    • Name of the files or information retrieved;
    • Date and time as well as duration of the retrieval;
    • Transferred data volume;
    • Operating system and information about the Internet browser used, including installed add-ons (e.g., Flash Player);
    • http status code (for example, “request succeeded” or “requested file not found”).

In the log files, the above data is stored without your complete IP address, so that it is not possible to trace back to your IP address.

2.1.1 Use of the website / data provided by you

We process personal data which we receive from you within the scope of our business relationship as journalist, photographer, influencer or other multiplier, or as a visitor of our website Audi MediaCenter, in accordance with the provisions of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act [Bundesdatenschutzgesetz, (“BDSG”)], for a variety of purposes.

This includes, in particular, the use of IT systems (e.g. websites, platforms) and communication tools, contact with employees or customer service, information we receive from your managers and colleagues, registration for newsletters, participation in training and continuing education, participation in events or the receipt of non-cash benefits, contact with audi ag press spokespersons, registration with the Audi MediaCenter and registration for press releases. The specific purposes for data processing are primarily focused on the functions and services that you use.

The Audi MediaCenter offers both publicly accessible content as well as content that is only available to logged-in users for whom personal registration is required. In addition, personally configurable newsletters are also offered.

The relevant personal data include:

    • professional contact details (e.g. professional address, e-mail and telephone number of company, department)
    • private contact data (e.g. title, sex, name, address, customer number, reporting date and, where applicable, required addresses, telephone numbers and e-mail address)
    • IT-usage data
    • Data entered when registering for events (e.g. date of birth, place of birth, ID number, passport information, special dietary needs and allergies)
    • Data from test vehicle bookings (e.g. a copy of your driving license, information about the test vehicle (model, time period), information about traffic violations and penalty charge notices)
    • Data on personal/professional circumstances and characteristics (e.g. tone of reporting, specialization in topical areas/departments, professional career – if publicly available)
    • Recordings (video, photo, sound)

We also process press articles and other pieces published by you about test drives or other topics related to AUDI either online or offline and which are available in the public domain (e.g. Internet, TV, radio, newspapers and magazines as well as other press products).

If you are an employee or belong to a governing body (e.g. Board of Management member) of AUDI AG, we process your personal data in the Audi Media Center for our company’s public relations purposes. These include e.g. batch articles posted on social media channels or other media reports.

Feedback function: In the feedback function you can provide us with an evaluation of our website. No personal data will be processed here.

Newsletter registration: On the website you can subscribe to our newsletter or order other marketing information. We process the contact information provided and interests expressed by you for this purpose, subject to your consent being given (Art. 6 (1) (a) GDPR). For the activation of the newsletter we use the so-called double opt-in procedure, i.e. we send you an e-mail to the given e-mail address with the request for confirmation of your consent. You may withdraw your consent for example by clicking the “unsubscribe” link included in each newsletter or contacting our customer service department. If you unsubscribe from the newsletter, your personal data will be deleted, unless we process your data on another legal basis, or if such data is subject to data retention requirements. The newsletter is dispatched by a processor.

Download basket: We also offer the option of collective download in a download basket. For the purposes of downloading a download basket, we process your email address for the duration of time the download basket is provided. 

In both cases, we store your data for technical administration and customer management, but only to the extent required for these purposes and only for the purpose defined on the website. We process your data with all due care and in compliance with all statutory security regulations to protect your data against unauthorized access and prevent abuse.

Making contact during updates to digital services: AUDI AG is subject to various legal and contractual requirements with which it must comply. These may be, for example, making contact during any updates to digital services in accordance with Section 327, letter F of the German Civil Code (Bürgerliches Gesetzbuch; the BGB) The following personal data will be processed for this purpose. Name, email, address. The legal basis for the associated data processing is compliance with a legal obligation within the meaning of Article 6(1)(c) GDPR or contractual obligations within the meaning of Article 6(1)(b) GDPR.

2.1.2 Further data

In addition we process - insofar as necessary in connection with personal data that we have obtained from publicly accessible sourcesand are permitted to process sources (e.g. press agencies, blogs, press reports, public websites, publicly accessible profiles in social media).

These include

    • professional contact details (e.g. professional address, e-mail and telephone number of company, department)
    • private contact data (e.g. title, sex, name, address, customer number, reporting date and, where applicable, required addresses, telephone numbers and e-mail address)
    • IT-usage data
    • Recordings (video, photo, sound)

Data processing in the context of cookies and user tracking as well as data processing for specific functions is all explained in the corresponding sections.

We process your personal data for various purposes in accordance with the provisions of the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act [Bundesdatenschutzgesetz (“BDSG”)].

You can find the specific purposes of the data processing in the context of this website in Section 3.

The processing of your personal data must be based on one of the following legal bases:

  • You have given your consent (Art. 6 (1) (a) GDPR);
  • Processing is necessary to perform a contract with you, or in order to take steps your request prior to entering into a contract (Art. 6 (1) (b) GDPR);
  • Processing is necessary for compliance with a legal obligation under EU law or under a Member State law to which we are subject (Art. 6 (1)(c) GDPR);
  • Processing is necessary to protect your vital interests or the vital interests of another person (Art. 6 (1) (d) GDPR);
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority which has been vested in us (Art. 6 (1) (e) GDPR);
  • Processing is necessary for the purposes of the legitimate interests pursued by the Audi AG or of a third party, except where these interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, particularly where this concerns a child (Art. 6 (1) (f) GDPR).

We process personal data that is required for participation in events, related to AUDI AG information, or related to vehicle test drives in order to take pre-contractual measures as well as to fulfill a particular contract based on Art. 6 para. 1 sub-section 1 (b) General Data Protection Regulation (GDPR), insofar as you are yourself a contractual partner.

If bookings are made via the medium for which you are active, we process your data based on the balancing of interests as per Art. 6 para. 1 sub-section 1 (f) GDPR. The legitimate interest of AUDI AG in this case is the fulfillment of the service agreed to via the medium in question. If we offer you the chance to participate in test drives or events, this is for the purposes of marketing based on consent as per Art. 6 Par. 1 Subpar. 1 Letter a) of the GDPR.

We process information regarding traffic violations that occur during a test drive as per Art. 6 para. 1 sub-section 1 letter c) GDPR in order to fulfill our legal disclosure obligations to traffic and law enforcement authorities. Insofar as penalty notices are forwarded, then that lies within AUDI AG’s legitimate interest as part of the balancing of interests as per Art. 6 para. 1 sub-section 1 (f) GDPR.

Furthermore, we process your personal data based on the balancing of interests as per Art. 6 para. 1 sub-section 1 (f) GDPR in order to manage our media contacts and assess publications about automobiles from AUDI AG and about AUDI AG itself. AUDI AG has a legitimate interest in managing media contacts and observing public reporting. In connection with this, AUDI AG also creates technical/professional profiles of journalists, influencers and multipliers to improve and focus how we approach those involved in interviews and the transfer of information.

To the extent that we, in exceptional cases, process special categories of personal data about you (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation), then one of the following legal bases must also apply:

  • You have given explicit consent (Art. 9 (2) (a) GDPR);
  • Processing is necessary to protect your vital interests or those of another person where the relevant person is physically or legally incapable for giving consent (Art. 9 (2) (c) GDPR);
  • Processing relates to personal data which you manifestly made public (Art. 9 (2) (e) GDPR);
  • Processing is necessary for the establishment, exercise or defence of legal claims (Art. 9 (2) (f) GDPR);
  • Processing is necessary for reasons of substantial public interest, on the basis of EU law or Member State law which shall be proportionate to the aim pursued, which shall respect the essence of the right to data protection and which shall provide for suitable and specific measures to safeguard your fundamental rights and interests (Art. 9 (2) (g) GDPR).

Following on from the above, we process your personal data on the basis of the following legal bases for the following purposes:

Purpose

Legal Basis

Legitimate Interest for Balancing of Interests

Provision of the website for the general public and for the purpose of enabling contact by customers and interested parties

Performance of the contract or balancing of interests

We have a legitimate interest in providing an Internet presence (website), also to unregistered users, in an effort to provide general information about our company.

Collection of statistical information on the use of the website (so-called “web analytics”)

Balancing of interests

We have a legitimate interest in receiving information about the use of the website including, in particular, for purposes of improving our offerings.

Identification of disruptions and assurance of system security, including detection and tracking of unauthorized access attempts and access to our web servers

Satisfaction of our legal obligations with respect to data security and balancing of interests

We have a legitimate interest in eliminating disruptions, ensuring system security, and detecting and tracking unauthorized access attempts.

Providing a download area as well as providing or delivering orders

Contractual fulfillment

Safeguarding and defending our rights

Balancing interests

We have a legitimate interest in exercising and defending our rights.

Press and public relations work

Balancing interests 

We have a legitimate interest in communication with multipliers and influencers on the Internet that is in line with their interests and consistent with the communication channels they use and the topics they address.

Providing a shopping basket

Performing or initiating a contract

Preparing a newsletter

Consent

In individual case we can process your data for the following purposes:

Purpose

Legal Basis

Legitimate Interest for Balancing of Interests

Support for law enforcement authorities in the event of vehicle theft by tracking vehicles and vehicle parts using the FIN

Public interest

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Prevention of fraud and money laundering

Fulfilment of legal obligations, balancing of interests

Compliance with legal and regulatory requirements

Prevention, combating and clarification of the financing of terrorism and crimes that pose a threat to property, comparisons with European and international anti-terror lists,

Fulfilment of legal obligations, balancing of interests

Compliance with legal and regulatory requirements

Compliance with fiscal control and reporting obligations, archiving of data

Fulfilment of legal obligations, balancing of interests

Compliance with legal and regulatory requirements

Disclosure within the scope of official/judicial measures for the purposes of gathering evidence, prosecution and enforcement of civil claims

Fulfilment of legal obligations, balancing of interests

Compliance with legal and regulatory requirements

Billing and tax valuation of operational services

Fulfilment of legal obligations, balancing of interests

Compliance with legal and regulatory requirements

Audit and special audits, internal investigations

balancing of interests

Verification of compliance with contractual and statutory obligations by AUDI AG, its employees and its sales partners, suppliers, etc., if necessary using the vehicle identification number

User survey (including a satisfaction survey)

consent

3.1 Is there an obligation to provide data?

In the context of our business relationship, you need to provide only the personal data that is required to enter into or conduct a business relationship or that we are required to collect by law. Without this data, we will generally have to refuse to enter into the contract or to execute the order, or we will be unable to perform under an existing contract and possibly may have to terminate it.

4 Who receives my data?

Due to the size and complexity of the data processing by the Audi AG, it is not possible to list each recipient of your personal data individually in this data protection notice, which is why usually only categories of recipients are specified.

Within Audi AG, your data is provided to the respective departments that need such data for data processing (e.g. sales division Audi training, sales Germany, IT)

Third-party service providers engaged by us and working on our order to support data processing (so-called “processors”) may also receive data for these purposes. We only use processors in Germany. For example, your e-mail address can be passed on to a service provider so that he can deliver an ordered newsletter to you. Service providers can also be commissioned to provide server capacity. This includes:

  • Other group companies, that provide services (e.g. IT services) for the AUDI AG
  • Consulting service providers
  • Print service providers
  • Archiving service providers
  • Hosting providers and support service providers
  • Event and travel agencies
  • IT service providers
  • Logistics and warehouse service providers
  • Tracking service providers (see Cookies and tracking)
  • Web agencies

Your personal data will be disclosed by us to third parties only if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in the disclosure, or if you have given your consent. In addition, data may be transferred to third parties to the extent we are required to do so by law or by enforceable regulatory or judicial order. Third parties to whom we may transfer your personal data, irrespective of the services we provide, include

  • Volkswagen AG within the framework of centralized group functions and group human ressources development
  • External consultants of the Audi AG (e.g. attorneys, tax consultant, chartered accountant)
  •  Project-related service providers (e.g. participant hotels, tour operators, airlines, caterers, chauffeur service, hostesses, lettershops)
  •  Insurance companies,
  •  Authorities within their jurisdiction (e.g. tax office, police, public prosecutor's office),
  •  Courts

Other third parties, if you instruct us to pass on data or give your consent

5. Are data transmitted to a third country?

A transfer of data to third countries (i.e., countries that are neither members of the European Union nor of the European Economic Area) may occur to the extent necessary to perform services for you, if required by law, or where you have given us your consent. In addition, we may also share your personal data withprocessors in third countries.

Please note that not all third countries have a data protection level recognized as adequate by the European Commission. For data transfers to third countries where there is no adequate level of data protection, before we share data, we will ensure that the recipient either has an adequate level of data protection (e.g., through self-certification by the recipient of the EU-US Privacy Shield or by agreement containing so-called “EU standard contractual clauses” of the European Union with the recipient) or if our users give their express consent.

Where we process your personal data as an employee or governing body member of AUDI AG for public relations purposes and you have given your consent, we will publish your personal data for worldwide access on the Internet. As part of this, your data will also be transferred to countries outside the European Union and the European Economic Area (known as “third countries”) which do not offer an appropriate level of data protection.

You can obtain from us a copy of the specific applicable or agreed provisions to ensure an adequate level of data protection. To do so, please use the information in the Contact section.

6. How long will my data be stored?

We store your data as long as necessary for the provision of our services to you or do so if we have a legitimate interest in the continued storage, especially for troubleshooting purposes.

The shopping cart will be stored for up to one month and is then deleted. You may delete the shopping cart anytime sooner on yourself.

In addition, we are subject to various retention and documentation requirements pursuant to, inter alia, the German Commercial Code (Handelsgesetzbuch - “HGB”) and the Tax Code (Abgabenordnung - “AO”). The retention and documentation periods specified therein last up to ten years. Finally, the storage period is also governed by statute of limitations periods, which can be up to thirty years, for example, pursuant to secs. 195 et seq. of the German Civil Code (Bürgerliches Gesetzbuch - “BGB”), whereby the general limitations period is three years.

Under certain circumstances, your data may need to be kept longer, e.g. if a legal hold or litigation hold (i.e. a ban on deleting data for the duration of the proceedings) is ordered in connection with official or judicial proceedings.

7 What rights do I have?

As the data subject, you are entitled to the following data protection rights:

Access:

You have the right to request accessto personal data related to you and stored at Audi AG and about the scope of data processing and data transfer performed by Audi AG and to obtain a copy of your stored personal data.

Rectification:

With respect to your personal data stored at Audi AG, you have the right to demand the immediate rectification of incorrect personal data and you have the right to have incomplete personal data completed.

Erasure:

You have the right to demand the immediate deletion or erasure of your personal data stored by Audi AG, if the legal requirements are satisfied.

This is the case, in particular, if

  • your personal data is no longer needed for the purposes for which it was collected;
  • the sole legal basis for processing such data was your consent, and you have withdrawn such consent;
  • you have objected to processing on the legal grounds relating to your particular situation, and we cannot prove that there are overriding legitimate grounds for processing;
  • your personal data were processed unlawfully; or
  • your personal data must be erased in order to comply with legal requirements.

If we have transmitted your data to third parties, we will inform them about the erasure to the extent required by law.

Please note that your right to erasure is subject to certain limitations. For example, we may not and/or must not erase data that we are still required to retain due to statutory retention obligations. In addition, your right of erasure does not extend to data that we need in order to assert, exercise or defend against legal claims, unless other grounds for continued storage exist.

Restriction to the Processing:

Under certain conditions, you have the right to request that processing be limited (i.e., the marking of stored personal data with the aim of limiting its processing in the future). The requirements are:

  • The accuracy of your personal data is contested by you and Audi AG must verify the accuracy of the personal data;
  • the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of their use instead;
  • Audi AG no longer needs the personal data for the purposes of processing, but you require the data to establish, exercise or defend your legal claims.
  • you have objected to processing pending the verification of whether the legitimate grounds of Audi AG override your legitimate grounds.

Where processing has been restricted, such data will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest the EU or an EU Member State.

Data Portability:

To the extent that we automatically process your personal data that you have provided to us based on your consent or any contract with you (including your employment contract), you have the right to receive such data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Audi AG. You also have the right to have the personal data transmitted directly from Audi AG to another controller where technically feasible, provided that such transmission does not adversely affect the rights and freedoms of others.

Right to Object:

If we process your personal data on grounds of legitimate interests or in the public interest, then you have the right to object to the processing of your personal data on grounds relating to your particular situation. In addition, you have an unrestricted right to object if we process your data for our direct marketing purposes. Please see our separate note in the section titled “Information about your right to object”.

In certain situations, in the context of a balancing of interests, we will grant you an additional unrestricted right to object.

Withdrawal of Consent:

If you have given consent to the processing of your personal data, then you can withdraw such consent at any time. Please note that the withdrawal applies prospectively only. Processing that occurred before the withdrawal of consent is unaffected.

Complaint:

Furthermore, you have a right to file a complaint with a data protection authority (Datenschutzaufsichtsbehörde), if you believe that the processing of your personal data is unlawful. The right to file a complaint is without prejudice to any other administrative or judicial remedies.

The address of the data protection supervisory authority responsible for Audi AG is:

Bayerisches Landesamt für Datenschutzaufsicht

Promenade 27 (Schloss)

91522 Ansbach

Deutschland

7.1 Information about Your Right to Object

Right to object for personal reasons

You have the right to object to the processing of your personal data on grounds relating to your particular situation. The prerequisite for this is that the data processing takes place in the public interest or on the basis of a balancing of interests. This applies also to profiling.

Insofar as we base the processing of your personal data on a balancing of interests, we generally assume that we can demonstrate compelling legitimate grounds but will, of course, examine each individual case.

In the event of an objection, we will no longer process your personal data, unless

    • we can demonstrate compelling legitimate grounds (zwingende schutzwürdige Gründe) for the processing of these data that override your interests, rights and freedoms, or
    • your personal data serves the establishment, exercise or defence of legal claims.

Objection against the processing of your personal data for product improvement and general customer analysis

As part of the balancing of interests, we grant you a separate right of objection with regard to the processing of your personal data for product improvement and general customer analysis.

If you object to the processing for purposes of product improvement and/or general customer analysis, we will no longer process your personal data for these purposes. Purely statistical evaluations of aggregated or otherwise anonymous data remain unaffected by this.

Exercise of the right of objection

The objection can be made without form and should preferably be made to the contact data listed in this data protection notice.

8. Special information on user tracking

Matomo

In order to keep the Audi MediaCenter offering up to date, user-friendly, and fully comprehensive, this website uses software from the web analytics provider Matomo that enables us to optimize our website to meet your needs. This data is used, for example, to simplify navigation – allowing us to further improve the user-friendliness of our services. The information generated in this process (including the IP address) is anonymized by default, making it impossible to track specific users. The information is only analyzed for reporting purposes after it has been anonymized.