Privacy Policy on the Processing of Personal Data in the Context of General Communication 

With this Privacy Policy, we inform you about the processing of your personal data by Volkswagen ADMT Hannover GmbH, Mecklenheidestraße 74, c/o Volkswagen Nutzfahrzeuge, mailbox 2570/0, 30419 Hannover, registered in the commercial register of the Hannover District Court, registration number HRB 222201 („Volkswagen ADMT Hannover GmbH“).

Volkswagen ADMT Hannover GmbH processes your data in accordance with the applicable data protection regulations. These requirements result in particular from the EU General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

More detailed information on data processing by Volkswagen ADMT Hannover GmbH can be found in the respective specific privacy policies.

We offer you various ways to contact us (e.g. business correspondence, ensuring customer service). Within the scope of general communication, we process the following personal data, for example: Your name, your e-mail address, your postal address and your telephone number.

We process personal data within the scope of general communication due to different legal bases and purposes. The legal basis for the processing of your personal data in connection with general communication always depends on the respective request and/or the respective business relationship. Below you will find an overview of the legal basis and purposes of data processing.

I. Performance of a contract and pre-contractual obligations

In the context of the initiation or execution of a contract as well as for the processing of your request, we only process the necessary personal data that you provide in this context. The purposes of the processing of personal data depend on the specific request within the contractual relationship with you and may include in particular

• General correspondence
• Processing of inquiries and orders by Volkswagen ADMT Hannover GmbH
• Transmission of inquiries and offers
• Further development of products, services and other measures for the control of business transactions and processes
• Processing of inquiries and complaints from interested parties and customers and business partners with regard to products and services of Volkswagen ADMT Hannover GmbH
• Assertion and examination of legal claims

The data processing is carried out on the basis of Art. 6 (1) point b) of regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”). In doing so, you must provide the personal data required to process your respective request or to prepare or carry out the business relationship with you. Without this data we will not be able to process your request or fulfil the contract with you.

II. Compliance with legal obligations or processing of personal data in the public interest

We also process your personal data in order to comply with legal obligations to which we are subject. These obligations may arise, for example, from commercial, tax, money laundering, financial, criminal, administrative, criminal procedural or civil law. The purposes of the processing result from the respective legal obligation. As a rule, the processing serves the purpose of complying with state obligations of control and information.

The data processing is carried out on the basis of Art. 6 (1) point c) or point e) GDPR. If we process personal data on the basis of a legal obligation or in the public interest, you must provide us with the personal data required to fulfil the legal obligation. Without the provision of such personal data, we may not be able to process the request or fulfil these obligations.

III. Requirement for the purposes of legitimate interests

Furthermore, your personal data will be processed to protect our legitimate interests or those of third parties. In particular, we pursue the following interests, which are also the respective purposes:

Conducting business correspondence with you or with your employer or client

• Transmission of inquiries and offers
• Further development of products, services, services and
• Support services and other measures to control business transactions and processes
• Ensuring the availability, operation and security of technical systems as well as technical data management
• Ensuring the availability, operation and security of technical systems as well as technical data management
• Responding to government inquiries and auditors
• Assertion and examination of legal claims

The data processing is carried out on the basis of Art. 6 (1) point f) GDPR. In cases in which you have to provide personal data for this purpose, we expressly point this out. Without the provision of such personal data, we may not be able to process your request or comply with your request.

We store your personal data as long as this is necessary for the purposes mentioned. In the event of an objection to processing on the basis of our legitimate interest (Art. 6 (1) point f) GDPR), we will delete your personal data, unless further processing is permitted under the relevant legal provisions. We also delete your personal data if we are obliged to do so for other legal reasons.

In accordance with these general principles, we delete personal data immediately after the legal basis ceases to apply, if they are no longer required for the purposes mentioned or if the purposes mentioned cease to apply and if there is no other legal basis (e.g. commercial and tax retention periods), otherwise after the other legal basis ceases to apply.

We will only pass on your personal data to external recipients outside Volkswagen ADMT Hannover GmbH if this is necessary to process or handle your request, if another legal permission or obligation exists or if we have your consent.

External receivers can be:

Data Processors:

Group companies of Volkswagen AG or external service providers that we use to provide services, e.g. in the areas of technical infrastructure and maintenance. To the extent that these service providers process personal data on our behalf, we have concluded a contract with these service providers. The service providers process the personal data solely for the purpose of performing their tasks and are contractually bound by our instructions.

Public authorities:

Authorities and state institutions, such as public prosecutors' offices, courts or tax authorities, to which we must transfer personal data for legally binding reasons. The transmission is then carried out on the basis of Art. 6 (1) point c) GDPR.

Private companies:

Volkswagen AG's affiliates, Volkswagen dealers, importers, cooperation partners, other business partners or auxiliary persons to whom personal data is transferred on the basis of your consent, for the purpose of processing an enquiry or fulfilling a contract with you or to protect our legitimate interests. The transmission is then carried out on the basis of Art. 6 (1) point a), point b) and/or point f) GDPR.

Recipients in third countries:

If data is transferred to recipients whose registered office or place of data processing is not located in a member state of the European Union or in another state that is a party to the Agreement on the European Economic Area, we ensure that, apart from exceptional cases permitted by law, the recipient either has an adequate level of data protection (e.g. where the European Commission has decided that the third country or the recipient ensures an adequate level of data protection) or the transfers is subject to appropriate safeguards such as standard data protection clauses adopted by the European Commission and agreed between us and the recipient or we obtain your consent.

You can assert your following rights towards Volkswagen ADMT Hannover GmbH at any time and free of charge. For further information on exercising your rights, please refer to section G.

Right of access: You have the right to obtain information from us about the processing of your personal data.

Right to rectification: You have the right to obtain rectification of any inaccurate or completion of any incomplete personal data concerning you.

Right to erasure: You have the right to obtain the erasure of your personal data if the conditions specified in Article 17 GDPR are met. Accordingly, you may obtain the erasure of your personal data, for instance, if it is no longer necessary for the purposes for which it was collected. Furthermore, you may obtain erasure if we process your personal data on the basis of your consent and you withdraw this consent.

Right to restriction of processing: You have the right to obtain the restriction of the processing of your personal data if the requirements of Article 18 GDPR are met. This is the case, for example, if you contest the accuracy of your personal data. For the duration of the verification of the accuracy of the personal data you can then obtain the restriction of the processing.

Right to object: If the processing is based on a legitimate interest or your personal data are used for the purpose of direct marketing, you may have the right to object to the processing of your personal data. In case of an objection, we kindly ask you to state the reasons for objecting to the data processing. In addition, you have the right to object to data processing for direct marketing purposes without giving a reason. This also applies to profiling in so far as it is related to direct marketing.

Right to data portability: If data processing is based on consent or contract performance and, in addition, is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.

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

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

Contact person for the exercise of your rights

You will find the contact persons for exercising your rights and further information on:
https://www.volkswagen-nutzfahrzeuge.de/de/elektrisch-und-autonom/autonomous-driving.html

Data protection officer

Our data protection officer is available to you as a contact person for data protectionrelated matters:

Data protection officer of Volkswagen ADMT Hannover GmbH

Berliner Ring 2
38440 Wolfsburg
dataprivacy@volkswagen.de