Privacy Policy for CustomizedSolution portal

  1. Privacy Policy

A. Process responsibility

Thank you for visiting a website of Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg, customizedsolution@volkswagen.de, entered in the register of companies at Braunschweig District Court under no. HRB 100484 (“Volkswagen AG”). Below, you will find information about the collection, processing and use of your data.
 

B. Use of the web page and log files

When you visit our web page, we process the following log files relating to you (these files contain no personally identifiable information and hence cannot be traced back to you):

  • An anonymous cookie ID, which does not allow your IP address to be identified
  • The operating system and web browser you are using, and your selected screen resolution
  • The date and time of your visit
  • The pages you visit on our website
  • The website from which you came to us and
  • The IP address of the device you are using to access the web page.

This data is processed in accordance with section 6(1)(b) GDPR. It is required for the proper display of the website. The data will be erased after 30 days. For more information about our cookies, go to our cookie guidelines.

Unless the following sections contain information to the contrary, data is processed on the basis of this contract (section 6(1)(b) GDPR) and exclusively by Volkswagen AG.

This web page is hosted by the processor Amazon Web Services (Amazon Web Services, Inc.). Some of the data processed includes the transmission of data to third countries (which are countries that are neither members of the European Union nor the European Economic Area). Please note that not all third countries have a data privacy level that is recognised as suitable by the European Commission. Where access to the data from such so-called insecure third state cannot be excluded, so-called EU standard contract clauses for the protection of your personal data were established as a suitable guarantee for data processing. You can access the EU standard contract clauses provided by the European Commission for this purpose here.
 

C. Collection, processing and use of your personal data

I. Login and registration for the Customized Solution Portal

The Customized Solution Portal (hereafter: CSP) is an online platform and the central access point for second stage manufacturers (hereafter: converter) who perform conversions on Volkswagen commercial vehicles. The CSP provides technical information, materials and services of Volkswagen Commercial Vehicles for product development and vehicle construction. The CSP is also used to maintain the partner system and attain partner status of Volkswagen Commercial Vehicles. 

Access to the CSP requires permanent access to the Group Retail Portal (hereafter: GRP). When GRP access is set up, a “GRP User ID” is created for the users. Once access is acquired, the CSP can be accessed via this platform. 

The following information is processed when a converter is registered in the CSP: first name, surname, email address, organisation ID, IT usage data (such as organisation ID, organisation type).

With this cooperation, employees of these companies can register as users in the CSP. The employee of the converter must also confirm in the “Warranty” category that the CSP must not be used for recalls that present a danger to life and limb. When creating the user account, the above-mentioned employee must continue to confirm use restrictions, such as personal responsibility for the provision and accuracy of information. These confirmations are stored in the CSP together with the GRP User ID (optional) of the GRP user and the user's email address. 

Volkswagen AG collects and processes the following personal data to verify your identity for the registration in the CSP:

First name, surname, company name, street address, postcode, city, country, email address, converter website address, IT usage data (such as language, time stamp).

We will only process your data as long as this is required for the above stated purpose and a related active user account GRP exists. We generally erase the data immediately after the legal basis ceases to apply, when it is no longer required for the purposes stated or the purposes stated cease to apply, and if there is no other legal basis (e.g. retention periods under commercial and tax law). The data will also be erased after the other legal basis or obligation for other legal reasons no longer applies. 

The collected data of an converter in the portal will be erased immediately at the contract end date unless other retention periods (such as retention period under tax law) are required. 

Data is processed on the CSP for the following processes:

III. CSP processes for registered users 

Partner application (Integrated Partner & Premium Partner)

As part of the Partner programme of Volkswagen Commercial Vehicles, a converter has the option to apply for an offered partner status. The current application status is stored in the profile for all applications throughout this process. This enables us to provide you with targeted support throughout the application process and prevent recurring questions.

The converter enters the required data and required declarations in the CSP to apply for the issue of the next higher partner status at Volkswagen Commercial Vehicles.

  • First name and surname
  • Email address
  • Phone
  • Website
  • Company logo
  • Employees
  • Role
  • Contact persons
  • Legal information
  • Sales revenue and sales figures of the company
  • Proof of product liability insurance
  • Proof of two-year warranty
  • IT usage data (such as time stamp, user)

The collected data will be erased immediately on the contract end date unless other retention periods (such as retention periods under tax law) are required.
 

Administration: Converter employee

The following information is recorded in the CSP: 

  • First name and surname
  • Email address
  • GRP User ID (optional)
  • Context ID

The collected data will be erased immediately on the contract end date of the relevant converter unless other retention periods (such as retention periods under tax law) are required.
 

Marketing consent agreement

Registered users and conversion managers of importers of the Volkswagen Commercial Vehicles brand receive, provided they have given their consent (section 6(1)(1)(a) GDPR), mailings with marketing materials related to customised solutions and invitations to events or information and invitations to marketing research studies.

The following data is used for sending the mails:

  • First name and surname
  • Email address
  • converter name
  • IT usage data (organisation ID, partner level)

The recipients of marketing information have the option to withdraw their consent (opt-out) in the login area under “User account” (as a registered user). Data provided in this context (email address and surname, first name) is exclusively used for the purpose of providing this service as part of your consent given (section 6(1)(1)(a) GDPR). You can withdraw your consent without stating reasons toward Volkswagen AG in your CSP profile management, by email to info-datenschutz@volkswagen.de contact details with future effect.

The collected data will be erased immediately on the contract end date unless other retention periods (such as retention periods under tax law) are required. 
 

Creation and administration: company profile and advertisements

Volkswagen AG provides a forum to all partners with partner status “Integrated Partner” and “Premium Partner” under www.customized-solution.com, where they can present their business in form of company profiles as well as their products in form of product advertisements.

The partner is personally responsible for creating a company profile and advertisements in accordance with the requirements of the Volkswagen AG Communication and Brand Guideline and the requirements stored in the CSP. Volkswagen AG will check the company profile and advertisement for compliance with the requirements prior to publication.

A company profile and advertisements can be published using an application (“Feature App”) if one is incorporated in the Volkswagen Commercial Vehicles web pages of the respective markets. The operator of the local Volkswagen Commercial Vehicles web pages is the respective Volkswagen importer, while the website is directly operated by Volkswagen AG in Germany. 

Volkswagen AG always ensures the transmission of the data from the CSP to www.customized-solution.com or the local web page.

The following data can be processed for the creation and administration of the company profile: 

  • Description of the company / company profile
  • Converter name
  • Language
  • Brochure (optional)
  • Photos
  • Photo descriptions
  • IT usage data (such as time stamp, version)
  • Converter name
  • Title of the advertisement 
  • Reference number
  • Product description
  • Photos
  • Photo name
  • Sector assignment
  • Vehicle basis
  • Vehicle information (payload, dimensions) (optional)
  • IT usage data (active/inactive, language)
  • Non-disclosure agreement
  • Information protection agreement
  • Title
  • Description
  • Desired ENT. Number
  • Desired file format by ENT number
  • Vehicle information (such as basic vehicle, model year, drive, etc.)
  • Email address
  • CAD order number
  • Converter name
  • First name and surname
  • B2b Profile ID
  • Second stage manufacturer
  • Sector
  • Purpose of the order
  • IT usage data (such as time stamp)

The collected data will be erased immediately on the contract end date unless other retention periods (such as retention periods under tax law) are required. 

The following additional data is processed as part of the creation and administration of advertisements:

The collected data will be erased immediately on the contract end date unless other retention periods (such as retention periods under tax law) are required.
 

CAD data order

Computer-aided design (CAD) provides support for design tasks using 3D data for vehicles of Volkswagen Commercial Vehicles. The provision of this data in the CSP supports converters in their design process from design development to the release to production. The following data is processed as part of the ordering process and the subsequent provision of the corresponding CAD data:

The collected data is anonymised no later than 30 days from its creation.
 

Adding or changing converter contact persons

The CSP gives converters the option to indicate contact persons for specific topics and store them in the CSP. The corresponding contact person is determined by the respective company and once entered serves as the contact person for the topic of CSP. You can erase or replace stored contact persons with new contact persons at any time.

The following data can be processed for adding or changing a contact person:

  • First name and surname
  • Role
  • Email address
  • Telephone (optional)

The collected data will be erased immediately on the contract end date of the relevant converter unless other retention periods (such as retention periods under tax law) are required.
 

Administration: WISA documents

As soon as you have completed the registration process for the CSP as a user, you will have the option to provide documents and information for the workshop information system (WISA) in the CSP. WISA enables you to quickly provide repair assistance in case of a claim via the Volkswagen AG service network. You can exchange your workshop information with our service network via WISA and thereby broaden your range for service and repair work.

The following data is processed in this context:

  • First name and surname
  • Email address
  • Language
  • Conditions
  • Annex to the conditions
  • Email address
  • URL Online Shop
  • Order form
  • Contact person (for service & repair, maintenance, replacement parts, warranty, qualification & training, etc.)
  • Vehicle identification number (VIN)
  • Warranty documents (e.g. vehicle model, types/versions, description of claim, etc.)
  • Maintenance documents (e.g. vehicle model, types/versions language, etc.)
  • Replacement part documents (e.g. vehicle model, types/versions, language, etc.)
  • Service & repair documents (e.g. vehicle model, types/versions language, etc.)
  • Qualification & training documents (e.g. vehicle model, types/versions language, etc.)
  • IT usage data (e.g. GRP ID and time stamp)
  • First name and surname
  • Role
  • Email address
  • IT usage data (number of participants, training participation yes/no)

The collected data will be erased immediately on the contract end date unless other retention periods (such as retention periods under tax law) are required.
 

Training registration

Users can obtain information of available trainings in the CSP. Users are partially obligated to participate by the existing sales guidelines. Additionally, employees of the converters who are not registered in the CSP themselves can be registered and participate in trainings. 

The CSP provides a detailed view of individual trainings to obtain the relevant information on the trainings. Following the registration, authorised users or registered third parties receive a confirmation by email.

Initially, we will process the following contact details:

that you have provided to us during your registration in the CSP to send you an invitation to the training and any subsequent necessary registration information or a link to the live online training. 

Volkswagen AG (commercial vehicles) will process your personal data for the purpose of the invitation to qualifications of employees. Processing takes place for the purpose of the invitation to face-to-face training and live online training.

The legal basis for data processing is an overriding legitimate interest of Volkswagen AG (see section (6)(1)(f) GDPR). 

The stored data is stored for a maximum of 30 days for the performance and post-processing of the training and subsequent training-related contact (such as to transmit the certificates of participation) unless we are required to store the data for a longer period of time due to retention and documentation obligations under tax and commercial law (e.g. from HGB, AO).
 

Body in white order

Converter with Integrated Partner or Premium Partner status and also importers, if they act in a role as converter, can request the configuration of bodies in white in the CSP. A body in white is configured in the CSP. The configuration is forwarded to the department where a final order is created from the request. 

The following personal data was processed for the configuration of trial bodies:

  • Company
  • Department
  • First name and surname
  • Phone
  • Email
  • Street address
  • Postcode
  • City
  • Country 
  • VAT ID
  • Note on the delivery
  • IT usage data (e.g. customer email, recipient email)

The collected data will be stored for technical tracking only and erased 30 days from the creation date unless other retention periods (such as retention periods under tax law) are required. 

If a contract is concluded for the ordering of a body in white, we process the data mentioned above for the execution of the contractual relationship and for invoicing. After the invoice has been issued, we process your personal data for a period of 15 years within the scope of tax retention obligations.
 

Order App

The customer-specific function control unit is a specific special vehicle control unit that enables various special functions in these vehicles using specific coding. The customer-specific function control unit provides converters with electronic access to the “Controller Area Network” (CAN network) of the Volkswagen commercial vehicle. An interface is provided in the CSP to initiate the order for a specific customer-specific function control unit. The forwarded order request includes data to process the order of the converter at the department for the inclusive configuration of the customer-specific function control unit. Only the data of the registered user will be forwarded. The data owner of the processed data is Volkswagen Commercial Vehicles and the GRP and CSP systems. 

The CSP forwards the following information for order processing: 

  • User ID
  • First name and surname
  • Email address
  • Converter name
  • Organisation ID
  • Street address
  • Postcode
  • City
  • Country 
  • Name of contact person
  • Email of contact person
  • Telephone number of contact person (optional)
  • IT usage data (e.g. User ID, user roles)

Orders for a configuration for the customer-specific function control unit can be placed via the CSP. The collected data will not be stored in the CSP.
 

Order data tracking

The second stage manufacturer can enter a commission or VIN number in the CSP and thereby assign a vehicle to be converted by them and schedule it. A list view provides a look at the current status and the estimated time of arrival for the queried vehicles.

The following data is additionally processed as part of order data tracking:

  • Commission numbers
  • Vehicle identification numbers (VIN)
  • Vehicle information (e.g. order status, paint colour, etc.)
  • IT usage data (active/inactive, language)

The collected data will be deleted no later than 30 days after successful order completion (status: vehicle arrived). Data processing is required for contract fulfilment (section 6(1)(b) GDPR).
 

D.  Adobe Analytics

This website uses the Adobe Analytics web analytics service to analyse access to this website by users. The data is processed on the basis of consent granted by you (section 6(1)(a) GDPR). 

To enable the analysis, cookies are stored on your device and used to collect information that also gets stored on the servers of Adobe Systems Software Ireland Limited (“Adobe”) as the processor acting on our behalf. As it is not possible to rule out that Adobe System Incorporated, based in the USA, may access information, appropriate EU standard data privacy clauses providing a reasonable data processing guarantee for non-European countries have been concluded. You have the right to be informed about this standard contract in the context of the provision of information.

The information stored on the Adobe servers cannot be directly associated with a specific person because Adobe Analytics is used with the settings “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed”. The setting “Before Geo-Lookup: Replace visitor’s last IP octet with 0” ensures that the IP address is anonymised prior to this geolocalisation by replacing the last eight numbers of the IP address with zeros. The user’s approximate location is added to the tracking packet, which still contains the full IP address, for statistical analysis. Before the tracking packet is stored, the IP address is then replaced by an individual fixed IP address – referred to as a generic IP address – if the “Obfuscate IP–Removed” setting has been configured. As a result, the IP address is no longer included in any of the data records stored. 

The data is processed on the basis of consent granted by you (section 6(1)(a) GDPR). You can withdraw your consent at any time with future effect by clicking on the following link: Cookie-Richtlinie | CustomizedSolution Portal (customized-solution.com)
 

E. Your rights 

You can exercise the following rights with respect to Volkswagen AG at any time and free of charge. Further information on exercising your rights is provided in section D. 

Right to information: you have the right to obtain information from us about how we process your personal data. 

Right to rectification: you have the right to request that we rectify any of your personal data that may be inaccurate or incomplete.

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

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

Right to object: you have the right to object to the processing of your data if the processing is based on an overriding interest or if your data is used for the purposes of direct marketing. If you object to the processing of your data, please notify us of the reasons for your objection. Furthermore, you have the right to object to data processing for the purposes of direct marketing. This also applies to profiling where this is connected to direct marketing. 

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

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

Right to lodge a complaint: you also have the right to lodge a complaint with a supervisory authority (e.g. the Data Protection Officer for the State of Lower Saxony) about our processing of your data.
 

F. Your contact persons

I. Contact persons for exercising your rights

The contact persons for exercising your rights and for further information can be found on the following web page https://datenschutz.volkswagen.de.
Data Protection Officer, Volkswagen AG
Berliner Ring 2, 38440 Wolfsburg
datenschutz@volkswagen.de



Version dated: July 2024