Model Year 2014-2019 Vehicles
Effective Date: January 1, 2020
[This Privacy Statement applies to all Model Year 2019 and older Volkswagen vehicles equipped with VW Car-Net Security & Service. If you have a newer Volkswagen vehicle, please see vw.com/privacy. You may contact us at VWCustomerCARE@vw.com or by phone, 24 hours a day, at 800-822-8987, for more information or if you are unsure which privacy statement applies to you.]
INFORMATION WE COLLECT AND HOW WE USE IT
- We obtain information about you and the Vehicle in the following ways: information you or your VW dealer or other VW affiliate or service provider provide to us when you buy or lease your Vehicle or register for Service;
- information obtained from VW Car-Net Security & Service Equipment in the Vehicle and your use of the Service;
- information you provide when you use the VW Car-Net Security & Service website or mobile application;
- information collected about your use of the Web sites or other online services of VW Car-Net Security & Service or our Service Partners;
- information provided by you directly, through communications between you and us (or our Service Partners);
- information obtained through publicly available or commercial sources; and
- information exchanged between us, our affiliates and our Service Partners.
We collect information about you and your Volkswagen vehicle (the "Vehicle") to facilitate the provision of VW Car-Net Security & Services. Providing these services involves a commercial relationship between you and us. Your use of VW Car-Net Security & Service may involve your interaction with our Service Providers, which include entities with whom you may interact directly such as roadside assistance and emergency service providers. We and our Service Partners require certain information from you to provide those services. When you activate your account and agree to the Terms of Service, we collect information about you as described below. We use this information to provide VW Car Net Security & Services and we may also use this information to establish your credit or protect against fraud and misuse.
- Identifiers, such as account information, including billing (including financial data used for payment purposes), settings, personalized services and authentication information.
- Commercial information, such as vehicle data transmitted from your vehicle or collected or inferred from your use of the vehicle or services, including general status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle including its identification, condition, equipment status, or collision information; vehicle/technology usage data; driver behavior data (such as vehicle speed, seat belt use, and information about braking habits; information that you provide when using the Car-Net Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers, or Integrated Content Providers or Optional Third Parties (defined below).
- Electronic activity, such as information about your use of Car-Net Services, the Car-Net mobile application, and the Car-Net website.
- Geolocation data.
- Voice command data(including any personal data included therein) combined with GPS location data, for the purpose of providing the requested service and to improve the voice command capabilities and features.
- Inferences from the information above, such as zip code of residence, length of commute, or frequency of individual versus multi-person use.
Please note that the information stored in your VW vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your VW vehicle or mobile device, and thus may be deleted, altered, or transferred.
Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.
We do not store the content of any messages (such as social media messages) that you transmit or access through Car-Net Services.
We may monitor or record conversations you have with our customer service representatives, emergency personnel, or the police, as well as your use of any of our or their automated services, for purposes such as assessing, maintaining or improving service quality; issue resolution; training; or promoting and providing services. You understand and agree to such monitoring and recording and you are responsible for notifying any users of your vehicle that this may occur. When you contact VW Car-Net Security & Service for the provision of services, we may collect caller identification information and the date and time of call. Our and our Service Partners’ customer service representatives may remain on the line while conferencing in a third party to assist in completing a service request.
We may use information about you and your Vehicle to customize VW Car-Net Security & Service for your use, analyze and troubleshoot VW Car-Net Security & Service and usage, improve our product offerings, maintain internal records, and communicate with you about VW Car-Net Security & Service or other products or services. For information about your choices regarding communications, refer to the Section of this policy entitled YOUR CONSENT AND CHOICE REGARDING COMMUNICATIONS.
DISCLOSURE OF YOUR INFORMATION
To provide VW Car-Net Security & Service, we share your information with Service Partners including, for example, roadside assistance providers and emergency service providers (e.g., 9-1-1) for the purpose of delivering VW Car-Net Security & Service to you. We may also share information about you and your Vehicle with service providers, i.e., third parties that perform services on our behalf, such as call centers, mailing vendors and Web site hosting companies. We may share information about the Vehicle and you with each other and our affiliated companies to facilitate research and to improve our product and service offerings, and with each other for marketing purposes.
We may share information about activation of the services with your Volkswagen dealer in order to allow the dealer to contact you. We also share pertinent information with law enforcement or others in case the stolen vehicle location assistance service has been requested. When required, we may release information to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law, or to enforce or apply the terms of our agreements with you or to defend ourselves or Volkswagen in a litigation. For example, we may be legally compelled to provide location data and other information to law enforcement agencies, pursuant to validly issued subpoenas or similar judicial or law enforcement procedures. We may also share your information with third parties for purposes other than as described in this policy with your consent.
We may share information with dealers and our affiliates to provide information about products and services that may be of interest to you. We may share information with Sirius XM radio in connection with their provision of satellite radio services.
We may share information with our business partners for joint marketing offers that may be of interest to you.
Should we declare bankruptcy or should our assets ever be acquired by or merged into another organization, the information we have collected about you and your Vehicle will be treated as an asset and may be transferred to a third party that purchases or otherwise acquires our assets.
UPDATING OR CHANGING YOUR ACCOUNT INFORMATION
It is your obligation to correct or update the information you provide upon activation of the VW Car-Net Security & Service when that information changes. You may review, update or change your information by calling one of our customer specialists at 1-877-820-2290 or writing to the Volkswagen Car-Net Security & Service Response Center c/o Verizon Connect, Inc., P.O. Box 422628, Atlanta, GA 30342.
PROTECTION OF INFORMATION
We employ administrative, technical and physical controls to protect against the loss of, or unauthorized access to, the information under our control. Although we take your privacy very seriously and we use responsible and reasonable practices to protect the privacy of your information, we cannot guarantee that your information will always remain secure.
SECURITY ON CELLULAR AND WIRELESS NETWORKS
The VW Car-Net Security & Service transmit voice and data between the response center and your Vehicle over wireless and cellular telephone networks. Although it may be illegal for unauthorized people to intercept these transmissions, we cannot guarantee the privacy and security of conversations or data transmitted to and from the Vehicle.
USE OF VW CAR-NET SECURITY & SERVICE WEB SITE AND MOBILE APPLICATIONS
When you browse the VW Car-Net Security & Service Web sites or use the VW Car-Net Security & Service mobile application, we collect information about you, your use of the services, and your device. For example, you may submit on our Web site your name, contact information, VIN, and the like. In addition, we collect information about your interactions with the VW Car-Net Security & Service Web site and mobile app, or Web sites of our Service Partners. We may collect and use your IP address and the Web site address of your point of entry to our sites, as well as other information about your connection, including your computer’s browser and platform type and your Internet connection speed, and your mobile device type and operating system version. We may collect and use information concerning the type of mobile device you use; the device’s operating system; information you provide via the device; the location of the device at the time of a service request; and other information as necessary to provide a VW Car-Net Security & Service. We use this information to monitor statistics such as how many people visit our Web sites and use our mobile apps, which pages people visit on our sites and how much time is spent on each page, which Web domains our visitors come from, which browsers are used to visit our sites, and how people use our mobile apps.
YOUR CONSENT AND CHOICE REGARDING COMMUNICATIONS
Please note that even if you choose not to receive marketing emails from us, you may still hear from us regarding the status of VW Car-Net Security & Service and any other service issues and order status updates that will allow us to provide you with an optimal user experience.
The VW Car-Net Security & Service Web site may contain links to other sites, including, among others, those of advertisers, other third parties, and companies whose trademarks may appear on the site. We are not responsible for the information collection practices or the content of the sites to which we link or for content and information collection practices of the Web sites and online services belonging to our Service Partners.
What is a Service Partner?
Service Partners are third parties that work with VW to provide services, equipment, content, features, or facilities connected with the provision of VW Car-Net Security & Service. Service Partners include, without limitation, telecommunications providers, call center operators, wireless service providers, public safety operators, emergency personnel, towing companies, vehicle distributors and dealers, equipment and software manufacturers, certain advertising companies and content providers or other third vendors acting on our behalf to provide the VW Car-Net Security & Service.
Service Partners may include Google, Inc’s map services, Parkopedia, and Spot Angels Information collected through such services is subject to the Service Providers’ respective privacy policies and is not governed by this policy.
YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information.
Please note that certain rights may be limited where your personal information is subject to certain state or federal laws, such as the Fair Credit Reporting Act ("FCRA), the federal Gramm-Leach-Bliley Act ("GLBA"), or the or the California Financial Information Privacy Act.
- Right to Opt-Out/Do Not Sell
California Consumers have the right to request that we not sell your personal information to third parties. However, even if you opt-out, we are allowed to continue sharing with service providers as permitted by law.
We will ask you for your personal information or information about you in order to match you with the data we have collected before executing the request.
For other data, you can submit a Request to Opt-Out by clicking , and following the instructions in the web form, or you can call (833) 909-1767.
- Right to Delete
California Consumers have the right to request that we delete personal information about you that we have collected from you. This right is subject to exceptions that allow us to retain data; for example, to service a contract or for our internal business purposes. We will not delete data subject to an exception. If you make a Request to Delete non-excepted data, we will not delete personal information on archived or backup systems until the archived or backup system is next accessed or used by restoring such data to live systems. We will also maintain a record of the Request to Delete as permitted by law.
You can submit a Request to Delete by clicking here and following the instructions in the web form or you can call (833) 909-1767. We will seek confirmation of your request.
For a Request to Delete, in order to verify your identity, match you to our records, and to reduce fraud, will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also use third party verification companies to help us verify your identify. If we are unable to find you in our records, or match the data you provide with what we have in our records, we will notify you.
- Right to Know
California Consumers have the right to request that we disclose personal information that we have about you. You can request either or both of the following types of reports;
- Categories Report that provides you with the categories of personal information we have collected in the 12 months preceding your request, at a minimum, and for each category: the categories of sources from which the personal information was collected; the business or commercial purpose for which we collected the personal information; the categories of third parties to whom we sold or disclosed the category of personal information for a business purpose; and the business or commercial purpose for which we sold or disclosed the category of personal information.
- Specific Pieces Report that provides you with the specific pieces of personal information that we have about you in the 12 months preceding your request, at a minimum.
For a Request to Know seeking a Specific Pieces Report, in order to verify your identity, match you to our records, and to reduce fraud, will ask you for your personal information or information about you. You will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also ask you to provide a signed declaration, under penalty of perjury, that you are the person whose personal information is the subject of the request. We may also use third party verification companies to help us verify your identify. If we are unable to verify your request for a Specific Pieces Report, we will treat it as a request for a Categories Report.
For a Request to Know seeking a Categories Report, you will need to provide certain pieces of information. The information you provide must match our records in a manner that we have determined to be reliable, for us to process your request. We may also use third party verification companies to help us verify your identify. If we are unable to verify your request for a Categories Report, we will direct you to the data handling practices in in our online privacy statements.
You can submit a Request to Know by clicking and following the instructions in the web form or you can call (833) 909-1767. California Consumers can submit a Request to Know twice in a 12 month period and the report will be provided free of charge.
If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above.
Use of authorized agent
If you are making any of the requests above as an authorized agent, we will require notarized written authorization or a notarized Power of Attorney. Additionally, we will seek to verify your identify in the manners stated above (depending on the request type). To make a request using an authorized agent please call (844) 987-2272.
Timing of Response:
For a Request to Opt-Out, we will process your request and update our records accordingly within 15 days.
For a Request to Delete or Request to Know Categories, we will strive to fulfill these requests within 45 days from the date we receive your request. If additional time is needed to complete any request, we will notify you that additional time is needed, tell you the reason that we need additional time, and tell you when you can expect your request to be completed.
For a Request to Know Specific Pieces Report, we may need an additional 45 day extension to respond to your request, as these requests will be burdensome and we will have to work with multiple systems and service providers in order to fulfill your request. Therefore, you can expect to receive your Specific Pieces Report within 90 days of your request.
We will maintain records of requests that are made that include the date of request, nature of request, manner in which the request was made, the date of our response, the nature of our response, and the basis for any denial of the request if it is denied in whole or part.
You are not required to create an online account with us in order to exercise your rights. However, for your convenience, we may offer you the option to create an account, so you may more easily exercise your rights in the future.
In accordance with applicable law, we will not discriminate against you for exercising your privacy rights.
You also have the right to request information from us regarding the manner in which we share certain categories of your personal information with unaffiliated third parties for the third parties’ direct marketing purposes. Written requests may be sent to the Office of General Counsel, Volkswagen Group of America, Attn: Privacy Office, 2200 Ferdinand Porsche Drive, Herndon, VA 20171 or by email to email@example.com. We will respond to these requests within 30 days of receipt. Requests that come to us by other means may result in a delayed response.
NEVADA PRIVACY RIGHTS
Nevada residents: please contact us at firstname.lastname@example.org to inquire about your right to opt out of the sale of your personal information.
CHANGES TO THIS POLICY
P.O. Box 422628
Atlanta, GA 30342-2628
For more information, call (877) 820-2290 or go to vw.com/carnet.
"Car-Net" is a registered trademark of Volkswagen Group of America, Inc. Apple, the Apple logo and iPhone are trademarks of Apple Inc., registered in the U.S. and other countries. App Store is a service mark of Apple Inc. "Android" and "Google" are trademarks or registered trademarks of Google Inc.