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Privacy information
Welcome to AutoVision – Der Personaldienstleister GmbH & Co. OHG, Major-Hirst-Straße 11, 38442 Wolfsburg, Germany datenschutz@avpdl.de,
A. General Section
I. Information about the collection of personal data
1. Hereinafter, we would like to inform you about the collection of personal data, which takes place during the use of our website (with the exception of the marketing function, which we will inform you about in the Special Section below). Personal data are all data, which relate to you personally, e.g. your name, your address, your telephone number, your e-mail address and your user behaviour. We thereby intend to inform you about our processing procedures and simultaneously fulfil the legal obligations, particularly from the EU General Data Protection Regulation (GDPR).
2. The controller in accordance with Art. 4 Para. 7 EU General Data Protection Regulation (GDPR):
AutoVision – Der Personaldienstleister GmbH & Co. OHG
(hereinafter: AutoVision)
represented by Sebastian Patta, Manfred Günterberg
Major-Hirst-Straße 11
38442 Wolfsburg
Germany
Tel.: +49(0) 5361 – 897-6100
E-Mail: info@avpdl.de
www.der-personaldienstleister.com
You can contact our Data Protection Representative at: datenschutz@avpdl.de or via our postal address (see above) with the addition of “the Data Protection Representative.”
3. If we intend to enlist the services of commissioned service providers for individual functions of our services for marketing purposes, we will always select and monitor these service providers diligently and will inform you in detail below about the relevant procedures. We will also inform you about the specified criteria for the storage duration.
II. Your rights
1. You have the following rights towards us regarding the personal data relating to you:
– Right to information,
– Right to correction or deletion,
– Right to restrict processing,
– Right to object to processing,
– Right to data portability.
2. You also have the right to complain to a data protection supervisory authority about the processing of your personal data in our company. The supervisory authority that is responsible for us is “Die Landesbeauftragte für den Datenschutz Niedersachsen”, Prinzenstraßen 5, 30159 Hannover, Telephone +49 (0511) 120 45 00, Telefax +49 (0511) 120 45 99, e-mail: poststelle@lfd.niedersachsen.de.
III. Processing of personal data when visiting our website
With the mere informational use of the website, i.e. if you do not register or otherwise send us information, we will process the personal data which your browser sends to our server. The data described below are technically required by us, in order to display our website to you and guarantee stability and security and must consequently be processed by us. The legal basis is Art. 6 Para. 1 S. 1 Letter f GDPR:
– IP address
– date and time of query
– time zone difference to Greenwich Mean Time (GMT)
– content of the request (visited site)
– access status/HTTP status code
– respective transferred data volume
– previously visited site
– browser
– operating system
– language and version of the browser software.
IV. Additional functions and services of our website
1. In addition to the purely informative use of our website, we offer various services, which you may visit, if interested, and we use additional standard functions for analysing or marketing our services, which are presented in further detail below. As a rule, additional personal data need to be provided for this or we process such additional data, which we use for performing the respective services. The aforementioned principles for data processing apply to all of the data processing purposes described here.
2. We sometimes enlist the services of external service providers to process your data. These are carefully selected by us, are bound to our instructions and are monitored on a regular basis.
3. Furthermore, we may pass on your personal data to third parties, if promotional participations, competitions, conclusions of contracts or similar services are offered by us in cooperation with partners. Depending on the service, your data may also be collected under the partners’ own responsibility. You can obtain further information when providing your data or below in the description of the respective services.
4. Insofar as our service providers or partners have their registered office outside of the European Economic Area (EEA), we will inform you about the consequences of this situation in the description of the service.
V. Revocation or objection to the processing of your data
1. If you have given consent to the processing of your data, you may revoke this at any time, free of charge. You may send the revocation by e-mail to info@avpdl.de or make a declaration by sending a message to the details indicated in the legal notice. Such a revocation influences the admissibility of processing your personal data, after you have made the declaration to us. The admissibility of processing your data until the time of your revocation remains unaffected.
2. Insofar as we base the processing of your personal data on the balancing of interests, you can file an objection against the processing. This is the case, if the processing is specifically not required for the fulfilment of a contract with you, which will be respectively presented by us in the description of the functions below. When exercising such an objection, we request the explanation of the reasons why we should not process your personal data, as performed by us. In the event of your objection, we will review the situation and will either discontinue and/or adapt the data processing or explain our compelling legitimate grounds, on the basis of which we will continue the processing.
3. You can of course object to the processing of your personal data for marketing and data analysis purposes at any time. It is best to exercise your objection to marketing using our contact details provided above.
VI. Processing of data from your terminal devices (“Cookie Policy”)
1. In addition to the aforementioned data, we use technical aids for various functions when you are using our website, particularly cookies, which may be saved on your terminal device. When you access our website and at any time later on, you have the option to generally allow the setting of cookies or which additional individual functions you would like to select. You can make changes in your browser settings or via our Consent Manager. In the following, we are initially describing cookies from a technical perspective (2.), before going into detail about your individual selection options, by describing technically necessary cookies (3.) and cookies that you can freely select or de-select (4.).
2. Cookies are text files or information in a database, which are saved on your hard disk and are allocated to the browser that you use, so that specific information can flow to the instance that sets the cookie. Cookies cannot execute any programs or transfer viruses to your computer, rather, their primary purpose is to make the Internet service faster and more user-friendly. This website uses the following types of cookies, whose functionality and legal basis we will explain below:
Transient cookies: These, particularly session cookies, are deleted automatically when closing the browser or by logging out. They contain a so-called Session ID. This way, different requests from your browser can be allocated to the common session and your computer can be recognised later on, if you return to our website.
Persistent cookies: These are automatically deleted after a specified period of time, which is defined differently, depending on the cookie. You can view the set cookies and the terms at any time and delete cookies manually in your browser settings.
3. Mandatory, technically necessary functions for displaying the website: The technical structure of the website requires us to use certain techniques, particularly cookies. Without these techniques, our website cannot be displayed (completely correctly) or the support functions could not be enabled. These are basically transient cookies, which are deleted after the end of your visit to the website, but no later than when you close your browser. You cannot de-select these cookies, if you would like to use our website. The legal basis of this processing is Art. 6 Para. 1 S. 1 Letter f GDPR.
4. Optional cookies upon granting your consent: We only set various cookies after your consent, which would can select when you first visit our website via the Cookie Consent Tool. The functions are only activated in the event of your consent and can particularly be used for us to analyse and improve your visits to our website, make it easier for you to use different browsers or terminal devices, recognise you when you visit or place ads (if applicable, also to base advertising on interests, measure the effectiveness of ads or show interest-based ads). The legal basis of this processing is Art. 6 Para. 1 S. 1 Letter a GDPR. The revocation of your consent is possible at any time, without the admissibility of processing until the revocation being affected.
VII. Web analytics
1. Google Analytics
a) This website uses Google Analytics, a web tracking service of Google LLC (“Google”). The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The purpose for using the tool is to enable the analysis of your user interactions on websites and in apps and improve our service and design them to be more interesting for you as the user, through the statistics and reports obtained. To simplify the administration of the tool, we use the Google Tag Manager (refer to 4. below).
b) We primarily record the interactions between you as the user of the website and our website, using cookies, data about the device/browser, IP addresses and the website or app activities. In Google Analytics, your IP addresses are also recorded, in order to ensure the security of the service and provide us, as the website operator, with information about which country, which region or which town the respective user originates from (“IP Tracking”). But for your protection, we naturally use the anonymisation function (“IP Masking”), i.e. within the EU/EEA, Google abbreviates the IP addresses by the last octet.
c) Google acts as a processor and we have concluded a relevant contract with Google. The information created by the cookie and the (usually abbreviated) IP addresses concerning your use of this website are generally transmitted to a Google server in the USA and processed there. According to its own account, Google has imposed a standard on itself, which corresponds to the former EU-US Privacy Shield and has agreed to comply with applicable data privacy law for international data transfer. We have also agreed standard contractual clauses with Google, whose purpose is compliance with an adequate data privacy level in a third country.
d) The legal basis for the collection and further processing of the information (which takes place for a maximum of 14 months) is you granted consent (Art. 6 Para. 1 S. 1 Letter a GDPR). The revocation of your consent is possible at any time, without the admissibility of processing until the revocation being affected. In apps, you can reset the advertising ID under the Android or iOS settings. It is easiest to install the revocation via the Google browser add-on, which can be accessed at the following link: tools.google.com/dlpage/gaoptout?hl=de/.
e) We can also check the success of our marketing campaigns by having Google link the information with Google Ads and other products used. You can disable the functions via the Ads Preferences Manager: <a href="https://adssettings.google.com/"adssettings.google.com. You can find additional information about the link at support.google.com/analytics/answer/6004245?hl=de/.
f) You can obtain further information about the scope of services of Google Analytics at marketingplatform.google.com/about/analytics/terms/de/. Google provides information about data processing using Google Analytics at the following link: support.google.com/analytics/answer/6004245?hl=de/. You can obtain general information about data processing, which also apply to Google Analytics, according to a statement by Google, in the Google Privacy Policy at policies.google.com/privacy?hl=de.
2. Bing Ads
This website uses Bing Ads, a programme by Microsoft Corporation, Microsoft Way Redmond, WA 98052- 7329, USA using Universal Event Tracking (UEN) to implement remarketing and closure tracking. A cookie is placed on the website visitor’s computer for this purpose when he or she visits our website via the Bing or Yahoo search engines. Data are collected and saved anonymously. By using the remarketing function, the user is presented with specially tailored offers in a subsequent search via one of the search engines mentioned above. Microsoft’s privacy policy regarding the handling of collected data can be viewed at the following link: https://privacy.microsoft.com/de-de/privacystatement/. Bing Ads can be deactivated at any time. To do so, please follow the instructions https://account.microsoft.com/privacy/ad-settings.
3. Indeed Conversion Tracking
This website uses the Conversion Tracking of Indeed Ireland Operations Limited, Block B, Capital Dock, 80, 2 Sir John Rogerson’s Quay, Dublin Docklands, Dublin, D02 HE36, Ireland. It places a cookie whenever a user clicks on a job advertisement that we have placed with Indeed. These cookies become invalid after 30 days and are not used for personal identification purposes. Once an application is completed, the cookie sends this information to the conversion – tracker, which counts the application receipt, i.e. one conversion. Every Indeed user receives a different cookie. Therefore, cookies cannot be tracked via the websites of Indeed ad customers. Information obtained via the conversion cookies is used to create conversion statistics. As a customer, we determine the total number of users that have clicked on our ad and completed an application. However, we do not receive any information that can be used to personally identify users. Personal data and the IP address are not collected. The same applies for Indeed Ireland Operations Limited.
If you do not wish to participate in tracking, you can object to its use by deactivating the Indeed Conversion Tracking cookie using your Internet browser under user settings. Subsequently, you will not be added to the conversion tracking statistics. The web address below will provide you with additional information about Indeed’s privacy policy (https://de.indeed.com/legal#privacypolicy).
4. Google Tag Manager
For the purposes of transparency, we would like to make it clear that this website uses Google Tag Manager. Google Tag Manager itself does not gather any personal data. Tag Manager makes it easy for us to integrate and manage our tags. Tags are small elements of code, which among other things, serve to track traffic and visitor behaviour, record the impact of online advertising and social channels, establish remarketing to, and alignment with, certain target groups as well as test and optimise websites. If you have deactivated something, Google Tag Manager will take this deactivation into account. For further information on Google Tag Manager, refer to: https://www.google.com/intl/de/tagmanager/use-policy.html
VIII. Online advertising
1. Google Ads
a) We use the Google Ads service to draw attention to our services using advertisements. If you end up on our website via a Google advertisement, a cookie will be saved in your terminal device by Google Ads. The legal basis for processing your data is Art. 6 Para. 1 S. 1 Letter a GDPR, i.e. the integration only takes place after your consent.
b) The advertisements are delivered by Google via “Ad Servers”. For this, we and other websites use Ad Server cookies, which can be used for success measurement through certain parameters, such as displaying the ads or clicks by the users. Through the Google Ads cookies that are stored on our website, we can obtain information about the success of our advertising campaigns. These cookies are not supposed to have the purpose of identifying you personally. As a rule, as analysis values for this cookie, the unique cookie ID, number of Ad Impressions per placement (frequency), last impression (relevant for post-interview conversions) and opt-out information (marking that a user no longer intends to be addressed) are stored.
c) The cookies set by Google enable it to recognise your Internet browser. If a user has visited specific web pages on the website of an Ads customer and the cookie stored on his computer has not yet expired, Google and the customer can identify that the user has clicked on the advertisement and was forwarded to the website. Each Ads customer is allocated a different cookie, so that the cookies cannot be tracked via the websites of other Ads customers. By integrating Google Ads, Google receives the information that you have accessed the corresponding part of our website or have clicked on one of our advertisements. If you are registered with a Google service, Google can allocate the visit to your account. Even if you are not registered with Google or logged in, the possibility exists that the provider will find out and store your IP address.
d) On the basis of the marketing tools used, your browser automatically establishes a direct link to the Google server. We do not personally collect personal data independently in the advertisements referred to, rather, we only provide the opportunity for Google to collect the data. We only receive statistical evaluations from Google, which provide information about which ads have been clicked on how often at which prices. We do not receive any further data from the use of the advertisements, in particular, we cannot identify the users on the basis of this information.
e) The revocation of your consent is possible at any time, without the admissibility of processing until the revocation being affected. It is easiest to perform the revocation via our Consent Manager or via the following functions: aa) with a relevant setting of your browser software, specifically, the suppression of third-party cookies leads to you not receiving any ads from third-party providers; bb) by setting your browser such that cookies from the “www.googleadservices.com” domain being blocked, www.google.de/settings/ads, whereby this setting will be deleted if you delete your cookies; cc) by deactivating the interest-based ads of the providers, who are part of the “About Ads” self-regulation campaign, via the www.aboutads.info/choices link, whereby this setting is deleted if you delete your cookies; dd) through permanent deactivation in your Firefox, Internet Explorer or Google Chrome browsers at the link www.google.com/settings/ads/plugin. We point out that in this case, you may possibly not be able to fully use all of the functions of this service.
f) You can find further information about data privacy at Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland, here: https://policies.google.com/privacy?hl=de and services.google.com/sitestats/de.html.
2. Google Conversion Tracking
a) We use Google Ads with the additional “Google Conversion Tracking” application. This is a procedure with which we can check the success of our advertising campaigns. For this, the ads are provided with a technical precaution, e.g. an ID, with which we can determine how a user interacts after clicking on the ads and whether one of our services is actually used. This way, we receive information in statistical form about the total number of readers of our ads, which ads are particularly popular and possible further information about the consequences of the ad.
b) The legal basis for processing your data is also Art. 6 Para. 1 S. 1 Letter a GDPR in this respect, i.e. the integration only takes place after your consent. You can prevent or no longer use the Conversion Tracking function, exactly as previously described regarding Google Ads.
3. Google Remarketing
a) We use Google Ads with the additional “Google Remarketing” application. With this procedure, we can create ads on the basis of existing information about you and address you again when you continue to use the Internet. This takes place by cookies set when visiting our services (usually through cookies), through which your user behaviour is recorded by Google and pseudonymised when visiting different websites. According to its own statements, Google does not combine the data collected within the scope of remarketing, which may be stored by Google, with your personal data.
b) The legal basis for processing your data is also Art. 6 Para. 1 S. 1 Letter a GDPR in this respect, i.e. the integration only takes place after your consent. You can prevent or no longer use the remarketing function, exactly as previously described regarding Google Ads.
IX. Social media
1. Integration of YouTube videos
a) We have integrated YouTube videos into our online service, which are stored on YouTube.com and are directly playable from our website. These are all integrated into the “extended data privacy mode”, i.e. that no data about you as the user are transferred to YouTube, if you do not play the videos. The data referred to in Para. 2 may only be transferred once you play the videos. We have no influence over this data transfer. The legal basis for the use of the plug-ins is Art. 6 Para. 1 S. 1 Letter a GDPR.
b) By visiting the website, YouTube receives the information that you have accessed the corresponding sub-site on our website. The aforementioned fundamental data, such as the IP address and time stamp, are also sent. This occurs, irrespective of whether YouTube provides a user account, through which you are logged in or whether no user account exists. If you are logged into Google, your data are allocated directly to your account. If you do not want the allocation to your profile with YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for advertising purposes, market research and/or needs-based design of its websites. Such an evaluation particularly occurs (even for users who are not logged in) for the provision of needs-based advertising and to inform other users of the social network about your activities on our website. You are entitled to a right object to the formation of these user profiles, whereby you must contact YouTube in order to exercise this.
c) The collected information is stored on Google servers, also in the USA. According to its own account, the provider has imposed a standard on itself, which corresponds to the former EU-US Privacy Shield and has agreed to comply with applicable data privacy law for international data transfer. We have also agreed standard privacy clauses with Google, whose purpose is compliance with a adequate data privacy level in a third country.
d) You can obtain additional information about the purpose and scope of the data collection and its processing by YouTube in the privacy policy. There, you will also receive further information about your rights and settings options to protect your privacy: https://policies.google.com/privacy?hl=de.
2. Our appearances in social networks
a) We have various appearances on social media platforms: YouTube (service provider: Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland), Xing (XING AG, Dammtorstraße 30, 20354 Hamburg, LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA).
b) For these information services, we use the technical platform and services of the providers. We point out that you are using our appearances on the social media platforms and their functions under your own responsibility. This particularly applies to the use of the interactive functions (e.g. sharing, commenting, rating). When visiting our appearances, the providers of the social media platforms record, inter alia, your IP address and additional information, which is available in the form of cookies on your terminal device. This information is used to provide us, as the operator of the account, with statistical information about the interaction with us.
c) The data collected about you in this context are processed by the platforms and possibly transferred to countries outside of the European Union, particularly the USA. According to their own account, all of the aforementioned providers maintain an adequate data privacy level, which corresponds to the former EU-US Privacy Shield and we have concluded the standard data privacy clauses with the companies (with the exception of Xing, as this provider has registered office within the EU). We are not aware, in which way the social media platforms use the data from your visit to our account and interaction with our posts for their own purposes, how long these data are stored and whether data are passed on to third parties. The data processing may differ according to whether you are registered and logged in with the social network or are visiting the site as a non-registered and/or non-logged-in user. With access to a post or the account, the IP address allocated to your terminal device is sent to the provider of the social media platform. If you are currently logged in as a user, a cookie on your terminal device can be used to track how you have moved in the Internet. Via buttons integrated into websites, it is possible for the platforms to record your visits on the websites and allocate them to your respective profile. On the basis of these data, contents or ads can be offered, which are tailored to you. If you would like to avoid this, you should logoff or deactivate the “stayed logged in” function, delete the cookies on your device and restart your browser.
d) We, as a provider of the information service, furthermore only process the data from your use of our service, which you provide us with and require an interaction. For example, if you ask a question, which we can only answer by e-mail, we will store your information according to the general principles of our data processing, which we describe in this privacy policy. The legal basis for the processing of your data on the social media platform is Art. 6 Para. 1 S. 1 Letter f GDPR.
e) To exercise your rights as a data subject, you can contact us or the provider of the social media platform. Insofar as a party is not responsible for answering or must obtain the information from the other party, we or the provider will then forward your enquiry to the respective partner. For questions about the profile formation, processing your data with use of the website, please contact the operator of the social media platform directly. For questions about the processing of your interaction with our website, write to the contact details provided by us above.
f) Which information the social media platform receives and how this is used is described by the providers in their privacy policies
policies.google.com/privacy?hl=de; https://privacy.xing.com/de/datenschutzerklaerung; https://de.linkedin.com/legal/privacy-policy. There, you can also find information about contact options and about the setting options for ads. You can find further information about social networks and how you can protect your data at www.youngdata.de.
X. Third-party links
We also offer third-party links. You can identify these by the fact that the link is identified by a brand symbol (e.g. the VW symbol of Volkswagen). If you click on this, you will reach the third party’s website. Although we check the offered links carefully, we point out that no influence exists whatsoever over the design and contents of the linked sites are not adopted as our own. AutoVision assumes no responsibility for handling your data on these websites. Please inform yourself in advance about the handling of personal data by these third parties.
XI. Making contact by e-mail, telephone or telefax
1. If you contact us via e-mail, telephone, or telefax, your enquiry will exclusively be stored and processed by use, including all of the resulting personal data (name, enquiry) for the purpose of processing your issue. We do not disclose these data without your consent.
2. The processing of these data occurs on the basis of Art. 6 (1) Letter b GDPR, if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interests in the effective handling of the enquiries directed towards us (Art. 6 Para. 1 Letter f DSGVO) or on your consent (Art. 6 Para. 1 Letter a DSGVO), if this has been requested.
3. The data sent by you with contact enquiries remain with us, until you ask us to delete them, revoke your consent to storage or if the purpose of the data storage ceases to exist (e.g. after completed processing of your inquiry). Mandatory statutory provisions – particularly retention periods – remain unaffected.
As at 12 November 2021
If you have additional questions regarding privacy at AutoVision – Der Personaldienstleister GmbH & Co. OHG or would like to provide suggestions regarding the matter, feel free to send your concern by e-mail or post to the following address:
Data Protection Officer at AutoVision – Der Personaldienstleister GmbH & Co. OHG
Volkswagen AG
Berliner Ring 2
38440 Wolfsburg, Germany