Privacy Policy

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We, Dr. Ing. h.c. F. Porsche AG (hereinafter referred to as “we” or “Porsche AG”), are happy about your interest in our digital community “Roads by Porsche” (hereinafter referred to as the “Online Service”). We take the protection of your personal data very seriously. Your personal data will be processed exclusively in accordance with the statutory provisions of data protection law, in particular the General Data Protection Regulation (hereinafter referred to as “GDPR”). With this Privacy Policy, we inform you about the processing of your personal data and about your rights as a data subject as affected in connection with the Online Service. For information on the processing of personal data in other areas, please refer to the respective specific privacy policies. If we refer to this Privacy Policy from external social media profiles, the following explanations apply only insofar as the processing takes place in our area of responsibility and insofar as no more specific and therefore prior information on data protection is provided in the context of such social media profiles.

1. Controller and data protection officer

Responsible for the data processing as controller in terms of data protection law is:

Dr. Ing. h.c. F. Porsche AG
Porscheplatz 1
70435 Stuttgart
Germany
Phone: +49 (0) 711 911-0
Email: info@porsche.de

If you have any questions or suggestions regarding data protection, please feel free to contact us. You can reach our data protection officer as follows:

Dr. Ing. h.c. F. Porsche AG
Data Protection Officer
Porscheplatz 1
70435 Stuttgart
Germany
Contact: www.porsche.com/international/privacy/contact/

2. Subject of data protection

The subject of data protection is the protection of personal data. This is all information relating to an identified or identifiable natural person (so-called data subject). This includes information such as name, postal address, email address or telephone number, but also other information that may be generated when using the Online Service, in particular information about the beginning, end and extent of use as well as the transmission of your IP address.

3. Purposes and legal basis of data processing

In the following, you will find an overview of the purposes and legal basis of data processing in connection with the Online Service. In any case, we process personal data in accordance with the legal requirements, even if in individual cases a different legal basis should be relevant than that stated below.

The provision of personal data by you may be required by law or contract or may be necessary for the conclusion of a contract. We will point it out separately if you are obliged to provide personal data and what possible consequences the non-supply would then have (e.g. a loss of claims or our position not to provide the requested service without providing certain information). The use of the Online Service is generally possible without registration. The use of individual functions may require prior registration. Even if you use the Online Service without registration, personal data may still be processed.

3.1 Performance of a contract and pre-contractual measures

We process your personal data if this is necessary for the performance of a contract to which you are a party or for the implementation of pre-contractual measures taken in response to your request. The data processing is based on Article 6 paragraph 1 letter b) GDPR. The purposes of processing include enabling the use of our specific products and services within the scope of the Online Service. Please also note the details in the respective documents describing our products and services further to this Privacy Policy. In particular, these are the following functions:

• Registration and login

We offer a registration and login procedure for our Online Service that includes the Porsche ID. This means that you do not have to remember any new login data for our Online Service. The Porsche ID and the corresponding service are provided by Porsche Sales and Marketplace GmbH (“PSM GmbH”). You can find the details on registering a user account for a Porsche ID in the privacy policy of PSM GmbH. If you decide to use the registration and login procedure involving the Porsche ID, you will be redirected to the PSM GmbH login/registration screen for the Porsche ID. Here you log in with your user name and password for the Porsche ID.

We will then receive a message from PSM GmbH that you have successfully registered and the registration or login for our online service will be completed. As part of the registration and login process, you can confirm to PSM GmbH that we may access the profile data of your Porsche ID user account. This means that you do not have to re-enter or maintain your profile data (e.g. if your address changes) in order to create your user profile for our Online Service. Conversely, changes to the profile data in the user account of our Online Service are then also synchronized accordingly in your user account for the Porsche ID. Data processing within the scope of the registration and login procedure involving the Porsche ID is based on Article 6 paragraph 1 letters b) and f) GDPR in order to register you with your user account for our Online Service or to identify you when you log in. We pursue – in addition to the implementation of the procedure or process requested by you – the interest of making the process of registration and login efficient and convenient. In this regard, we are jointly responsible with PSM GmbH and jointly determine the purposes and means of processing personal data in relation to the process. In an agreement on joint control pursuant to Article 26 GDPR, we have defined how the respective tasks and responsibilities for the processing of personal data are structured and who fulfils which obligations under data protection law. In particular, we have determined how an appropriate level of security and your data subject rights can be ensured, how we can jointly fulfil data protection information obligations, and how we can monitor potential data protection incidents. This also includes ensuring that we can fulfil our reporting and notification obligations. Insofar as you contact us, we will coordinate in the sense of the addressed agreement according to Article 26 GDPR in order to answer your inquiry and ensure your data subject rights.

Alternatively, you can use a so-called “single sign-on procedure” for registration and login by integrating the services of third party providers. With the help of the single sign-on procedure, you can register and log in as a logged-in user of Facebook (service provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) or Apple (service provider: Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA). If you decide to use the single sign-on procedure, you will be redirected to the login/registration screen of your account with the respective provider through which the single sign-on procedure is handled. Here you log in with your user name and password. We receive a message from the provider that you have successfully logged in and the registration or login is completed. During this process, we do not come into contact with your password or your user name at the provider that handles the single sign-on procedure. Upon successful registration or login, you must confirm to the provider that we may access your basic profile data (name, photo URL, user ID, e-mail). This way you do not have to maintain your basic profile data again and keep it up to date (e.g. if your e-mail address changes). If you decide to remove the link to the account with the provider through which the single sign-on procedure is handled, the corresponding settings are available to you with this provider.

• User profile

Mandatory information required for registration and creation of a user profile is marked with an “*” at the respective input field:

  • User name
  • Email address
  • Preferred vehicle manufacturers
  • Driving preferences
  • Handle

Registration is not possible without providing the mandatory information. When creating a user profile, you have the option of providing additional information on a voluntary basis.

  • First name
  • Last name
  • Gender (sex)
  • Age of user
  • Place of residence
  • Preferred topics
  • Spoken languages
  • Personal information (free text)
  • Current status (free text)
  • Vehicle(s)
  • Porsche Club Membership
  • User avatar image
  • Links to social media profiles

Please note that this information is not required for registration and you alone decide whether to provide us with this data. If you do not provide this data, we may not be able to fully accommodate your requests when using this feature. The data you provide will be used by us to create your user profile. Your user profile can be accessed by us and other users and searched for the information it contains.

• Dashboard

When you use the Dashboard, the following categories of personal data are processed:

  • GPS location
  • Entered region(s)

This is voluntary information. However, if you do not provide this information, we may not be able to fully address your needs when using the Dashboard. The Dashboard requires your device’s GPS signal to provide localized content.

• Route catalogue and route navigation

When you use the route catalogue and route navigation, the following categories of personal data are processed:

  • GPS position
  • ID and category of the routes for which you have given a rating, reaction or comment
  • ID and category of the routes travelled
  • Time of the routes travelled
  • Total percentage of routes travelled

This is voluntary information. However, if you do not provide this information, we may not be able to fully address your needs when using route navigation. Route navigation requires your device’s GPS signal to provide functioning in-app turn-by-turn navigation and a localized catalogue of routes..

• Route creation

When you use route creation, the following categories of personal data are processed:

  • GPS position
  • Entered destination and intermediate destinations
  • Search inputs
  • Preferred route parameters and properties
  • Planned start time
  • Description (free text)
  • Preferred season
  • Pictures and videos
  • Planned vehicle use

This is voluntary information. However, if you do not provide us with this data, we may not be able to fully address your needs when using route creation. Route creation requires your device’s GPS signal to provide a working route calculation. The following processing is performed as part of the route calculation:

  • Calculation of the route
  • Analysis of the route
  • Matching of the calculated route with current map waypoints to ensure proper routing
  • Inclusion of prominent navigation points along the route
  • Calculation of the total travel time
  • Calculation of the total length
  • Calculation of the weather
  • Calculation of traffic conditions
  • Posting user content

You can post your own content such as comments and recommendations as well as photos and videos or distribute “likes” to content or third-party user content, which is then linked to your user profile. This user content can be accessed by us and the other users.

• Networking with other users

Within the framework of the Online Service, you can interact with the community of other users or follow them in order to stay in contact with them or to be informed about their user content. In this respect, you can also mark and mention other users so that their user profile is linked to the user content. In this sense, other users can also perform these functions with you or your user profile.

3.2 Compliance with legal obligations

We process your personal data to comply with legal obligations to which we are subject. The data processing is based on Article 6 paragraph 1 letter c) GDPR. These obligations may arise, for example, from commercial, tax, money laundering, financial or criminal law. The purposes of the processing result from the respective legal obligation; as a rule, the processing serves the purpose of complying with state control and information obligations.

3.3 Safeguarding of legitimate interests

We also process your personal data to pursue the legitimate interests of ourselves or third parties, unless your rights, which require the protection of your personal data, outweigh these interests. The data processing is based on Article 6 paragraph 1 letter f) GDPR. The processing to safeguard legitimate interests is carried out for the following purposes or to safeguard the following interests.

  • Further development of products, services and support offers as well as other measures to control business transactions and processes;
  • Improvement of product quality, elimination of errors and malfunctions;
  • Handling of non-contractual inquiries and concerns;
  • Ensuring legally compliant actions, prevention of and protection against legal violations (especially criminal offences), assertion of and defence against legal claims, internal and external compliance measures;
  • Ensuring availability, operation and security of technical systems as well as technical data management;
  • Answering and evaluation of contact requests and feedback.

When you call up the Online Service, data relating to your end device and your use of the online offer are processed and stored in a so-called log file. This concerns in particular technical data such as date and time of access, duration of the visit, type of terminal device, operating system used, functions used, amount of data sent, IP address and referrer URL. We process this data to ensure technical operation and to determine and eliminate faults. In doing so, we pursue the interest of permanently ensuring technical operability. We do not use this data for the purpose of drawing conclusions about your person.

3.4 Consent

We process your personal data on the basis of corresponding consent. The data processing is based on Article 6 paragraph 1 letter a) GDPR. If you give your consent, it is always for a specific purpose; the purposes of processing are determined by the content of your declaration of consent. You may revoke any consent you have given at any time, without affecting the legality of the processing that has taken place on the basis of the consent until revocation.

3.5 Change of purpose

If we process your personal data for a purpose other than that for which the data was collected, beyond the scope of a corresponding consent or a mandatory legal basis, we will take into account, in accordance with Article 6 paragraph 4 GDPR, the compatibility of the original and the now pursued purpose, the nature of the personal data, the possible consequences of further processing for you and the guarantees for the protection of the personal data.

3.6 Profiling

We do not carry out automated decision making or profiling in accordance with Article 22 GDPR. Profiling is only carried out to protect our legitimate interests as described above.

4. Access authorizations in the end device

To the extent functions of the Online Service require the granting of authorization to access your end device (e.g. access to location data or photos), the granting of these authorizations is voluntary. However, if you wish to use the corresponding functions, you must grant the appropriate authorizations, otherwise you will not be able to use these functions. The permissions remain active as long as you have not reset them in your device by deactivating the respective setting.

5. Cookies and comparable technologies

We use cookies and comparable technologies in connection with the Online Service which serve to communicate with your end device and exchange stored information (hereinafter collectively referred to as “Cookies”). These Cookies are primarily used to make the functions of the Online Service usable. General examples in which the use of Cookies is technically required in this sense are the storage of a language selection, login data or a shopping or watch list. Accordingly, technically required Cookies may be used by us to enable the processing described in section 3.1 and to ensure the proper and secure operation of the Online Service.

The data processing is then carried out on the basis of Article 6 paragraph 1 letters b) and f) GDPR, as it is necessary to implement the functions you have selected or to protect our legitimate interest in the functionality of the Online Service. Insofar as we should also use Cookies in order to analyse the use of the Online Service and to be able to target it to your interests and, if necessary, to provide you with interest-based content and advertisements, this is done exclusively on the basis of your voluntary consent in accordance with Article 6 paragraph 1 letter a) GDPR. We use the service Google Analytics for Firebase provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland to track which content is relevant to users and, based on this, to continuously improve the quality of our Online Service and optimize the user experience, to measure the reach and success of marketing activities, to measure and improve the performance of our Online Service, and to adapt content to the needs of users. You have the opportunity to make the appropriate settings within the Online Service via the consent management. You may revoke any consent you have given at any time with effect for the future.

If you do not wish to use Cookies in general, you can also prevent their storage by adjusting the settings of your end device accordingly. Stored Cookies can be deleted at any time in the system settings of your terminal device. Please note that blocking certain types of Cookies can lead to impaired use of the Online Service.

6. Integrated third-party services

Insofar as we integrate services of other providers within the scope of the Online Service in order to provide you with certain content or functions (e.g. playing videos or route planning) and we process personal data in the process, this is done on the basis of Article 6 paragraph 1 letters b) and f) GDPR. This is because the data processing is then necessary to implement the functions you have selected or to protect our legitimate interest in an optimal range of functions of the Online Service. Insofar as Cookies may be used within the scope of these third-party services, the statements under Section 5 apply. Please also refer to the privacy policy of the respective third-party provider with regard to the third-party services.

Services of other providers which we integrate or to which we refer are provided by the respective third parties. We have no influence on the content and function of the third-party services and are generally not responsible for the processing of your personal data by their providers, unless the third-party services are completely designed on our behalf and then integrated by us on our own responsibility. Insofar as the integration of a third-party service results in us establishing joint processes with its provider, we will define with this provider in an agreement on joint controllership pursuant to Article 26 GDPR how the respective tasks and responsibilities in the processing of personal data are structured and who fulfils which data protection obligations. Insofar as Cookies are to be set on the basis of your consent, you will receive further information on the responsibility for setting these Cookies and any associated third-party services in the corresponding area of the consent management.

Unless otherwise stated, profiles on social media are generally only included in the Online Service as a link to the corresponding third-party services. After clicking on the integrated text/image link, you will be redirected to the offer of the respective social media provider. After the redirection, personal data may be collected directly by the third-party provider. If you are logged in to your user account of the respective social media provider, the provider may be able to assign the collected information of the specific visit to your personal user account. If you interact via a “share” button of the respective social media provider, this information can be stored in the personal user account and published if necessary. If you want to prevent the collected information from being assigned directly to your user account, you must log out before clicking the included text/image link.

7. Recipients of personal data

Within our company, only those persons who need your personal data for the respective purposes mentioned have access to it. Your personal data will only be passed on to external recipients if we have legal permission to do so or have your consent. Below you will find an overview of the corresponding recipients:

  • Commissioned processors: Group companies or external service providers, for example in the areas of technical infrastructure and maintenance as well as route navigation and calculation, which are carefully selected and reviewed. The processors may only use the data in accordance with our instructions.
  • Public bodies: Authorities and state institutions, such as tax authorities, public prosecutors’ offices or courts, to which we (must) transfer personal data, e.g. to fulfil legal obligations or to protect legitimate interests.
  • Private bodies: Group companies, Porsche sales companies (incl. companies offering services in the area of Porsche Connect and Smart Mobility), dealer and service operations, cooperation partners, service providers (not bound by instructions) or commissioned persons such as Porsche Centres and Porsche Service Centres.

8. Data processing in third countries

If a data transfer takes place to entities whose registered office or place of data processing is not located in a member state of the European Union, another state party to the Agreement on the European Economic Area or a state for which an adequate level of data protection has been determined by a decision of the European Commission, we will ensure prior to the transfer that either the data transfer is covered by a statutory permit, that guarantees for an adequate level of data protection with regard to the data transfer are in place (e.g., through the agreement of contractual warranties, officially recognized regulations or binding internal data protection regulations at the recipient), or that you have given your consent to the data transfer.

If the data is transferred on the basis of Articles 46, 47 or 49 paragraph 1, subparagraph 2 GDPR, you can obtain from us a copy or reference to the availability of the guarantees for an adequate level of data protection in relation to the data transfer. Please use the information provided under Section 1.

9. Storage duration, erasure of data

We store your personal data, if there is legal permission to do so, only as long as necessary to achieve the intended purposes or as long as you have not revoked your consent. In the event of an objection to processing, we will delete your personal data, unless further processing is still permitted by law. We will also delete your personal data if we are obliged to do so for other legal reasons.

Applying these general principles, we will usually delete your personal data immediately

  • after the legal permission has ceased to apply and provided that no other legal basis (e.g. commercial and tax law retention periods) intervenes. If the latter applies, we will delete the data after the other legal basis has ceased to apply;
  • if your personal data is no longer required for the purposes we pursue and no other legal basis (e.g. commercial and tax law retention periods) intervenes. If the latter is the case, we will delete the data after the other legal basis has ceased to apply.

10. Rights of data subjects

Right to access: You have the right to receive information about your personal data stored by us.

Right to rectification and erasure: You can demand that we correct incorrect data and, if the legal requirements are met, delete your data.

Restriction of processing: You can demand that we restrict the processing of your data, provided that the legal requirements are met.

Data portability: If you have provided us with data on the basis of a contract or consent, you may, if the legal requirements are met, demand that the data you have provided us with are handed over in a structured, common and machine-readable format or that we transfer it to another controller.

Objection: You have the right to object at any time to data processing by us based on the safeguarding of legitimate interests for reasons arising from your particular situation. If you make use of your right to object, we will stop processing the data unless we can prove compelling reasons for further processing worthy of protection which outweigh your rights and interests.

Objection to direct marketing: If we process your personal data for the purpose of direct marketing, you have the right to object to our processing of your data for this purpose at any time. If you exercise your right to object, we will stop processing your data for this purpose.

Revocation of consent: If you have given us your consent to process your personal data, you can revoke it at any time with effect for the future. The legality of the processing of your data until revocation remains unaffected.

Right to lodge a complaint with a supervisory authority: You can also lodge a complaint with the competent supervisory authority

if you believe that the processing of your data violates applicable law. You can contact the supervisory authority responsible foryour place of residence or your country or the supervisory authority responsible for us.

Your contact with us and the exercise of your rights: Furthermore, you can contact us free of charge if you have questions regarding the processing of your personal data and your rights as a data subject. Please contact us at https://www.porsche.com/privacycontact/ or by letter mail to the address provided under Section 1. Please make sure that we can definitely identify you. If you revoke your consent, you can alternatively choose the contact method that you used when you gave your consent.

11. Effective date

The latest version of this Privacy Policy applies. This version dates from 03.03.2023.

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