Privacy Policy

This privacy policy explains how Volkswagen Group Australia Pty Ltd (ABN 14 093 117 876) (“VGA”, “we”, “us” or “our”) controls and processes your personal information in connection with the GoConnect Application (“Application” or “App”), which is powered by Connected Cars A/S (a Danish company) (“Connected Cars”). The App helps vehicle owners and drivers harness the power of the vehicle’s technical data.

1 - Introduction

This privacy policy (“Privacy Policy”) describes how we collect and handle your personal information. We urge you to read the Privacy Policy thoroughly, and you will be asked to confirm that you have read and understood the Privacy Policy when you sign up for services via the GoConnect App.

Throughout this Privacy Policy, we refer to “CC-Link”, which is a hardware plug-in device connected to a vehicle’s on-board diagnostics (“OBD”) box that is used to collect vehicle data. Once you have downloaded the App and given your consent to the collection of data (and you are a primary user of the vehicle), the vehicle data is transmitted to Connected Cars and shared with VGA and your nominated dealership. Primary and secondary users can also see various data collected through use of the App. Further information is provided below.

“You” means:

  • the owner and/or the primary user of the vehicle in which the CC-Link is installed. The owner and/or primary user is invited to use the App by their preferred dealership; and

  • additional (or secondary) users of the vehicle who the primary user invites to use the App.

2 – What personal information is collected?

Your personal information which may be collected includes:

  • A. Your contact details, including your full name, postal address, email address and phone number;

  • B. Your preferred dealership;

  • C. General information about your vehicle such as the vehicle model, VIN number and registration number;

  • D. Identification documents;

  • E. Your preferences for receiving marketing communications;

  • F. Information collected from marketing campaigns, product research and customer surveys;

  • G. Information collected using cookies such as when you use the App (please see Connected Cars’ Cookie Policy for more information); and

  • H. Meta-data about the service provided to the primary and secondary users on the registered vehicle, including information related to time and completion of requests.

The following additional information is collected in respect of your vehicle and/or via your use of the App:

  • the CC-Link identifier which is allocated to your vehicle by Connected Cars;

  • technical information related to your vehicle, including (but not limited to) data related to fuel consumption, the odometer, error codes, warning lights and service indications;

  • GPS location data about the routes taken by the vehicle and where the vehicle is parked (if this function has been activated by the primary user);

  • accelerometer data, which measures changes in speed, turning and braking and is used to calculate a driver score (if this function has been activated by the primary user).

Unless the primary user has enabled GPS location data to be collected, no GPS location data will be collected in respect of any trips taken in the vehicle (regardless of who is the driver). The primary users may restrict access to geo-location data so that only the primary user can see this data. Secondary users cannot disable the GPS location-data function unless the primary user has disabled geo-location tracking on the Application for all users.

3 – How is your personal information used?

The personal information collected is generally used for the following purposes, where the references in the parenthesis reference the categories of personal data:

  1. Creation of your user profile and account including to verify your identity. (A).

  2. General management of your account and provision of services requested by you (A and B), such as booking service appointments, instant chat with your preferred authorised dealership, seeking breakdown assistance via the Volkswagen Assist option and obtaining advice or a quote for repairs based on the precise condition of your vehicle.

  3. General support regarding your use of the App. (A-G).

  4. Analyse data from the car in order to ensure the data quality before displaying the data to you in the App and to support the features you have activated in the App (eg. “my trips”, “fuel usage”, “driving events”) so that you can view, for example, your trip history, see your vehicle’s location, understand your driving behaviour, receive notifications about errors and alarms and monitor the vehicle’s battery and fuel levels.(E).

  5. Send you service announcements, notices and other changes to the App, Conditions of Use, the Privacy Policy or the Cookie Policy and to communicate with you where you contact us (including via social media). (A, B and G).

  6. Preparation of statistics concerning our services and further development of our services. (G).

  7. Business, process and product development, optimisation of customer functionality and elimination of product defects related to our services, in connection with VGA and dealerships. (C)

  8. Improving our services including our social media profiles and pages. (A, D)

  9. Marketing, such as sending you information about products that may interest you (where you have provided consent). Should you no longer wish to receive marketing messages, you can unsubscribe at any time by updating your marketing preferences in the App or following the unsubscribe instructions in any marketing message. (A, B and F)

Secondary users: If you are a secondary user, the primary user is responsible for choosing the level of data which is shared with you, for example, the primary user may restrict your ability to access GPS location data. Secondary users can see the full name and email address of the primary user and other secondary users. The location of the vehicle is also shared if this function is enabled by the primary user. If the primary user does not share the location, then no one can see the live location of the vehicle, but they can assign driven trips and see where the vehicle has been, but this is only visible to the assigned driver. If you wish to no longer be connected to the vehicle, please request the primary user to remove you (which they can do via the App).

Without certain personal information we may not be able to provide our services to you.

Security: We store your personal information in electronic format and hardcopy and take reasonable steps to ensure that the personal information is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. However, as the transmission of information across the internet is not completely secure we cannot guarantee the security of your personal information transmitted to our website. Any such transmission is at your own risk.

If you are no longer the primary user/owner of the vehicle (including if you sell the vehicle) you must close your user account or delete the vehicle from your user account in accordance with the Conditions of Use. This will ensure that data ceases being collected from the vehicle after disposal by the primary user. Please note that if you delete the Application, certain lead generation data will continue to be collected about the vehicle and its use, including the kilometres travelled and battery function. To stop lead generation data from continuing to being collected, either close your user account or delete your vehicle from the Application.

4 – How is your personal information collected?

Your personal information is collected from the following sources:

  • Directly from you and secondary users of the vehicle;

  • Directly from the vehicle via the CC-Link (provided by Connected Cars);

  • VGA dealership network;

  • Managers of fleets where vehicles have been fitted with a CC-Link;

  • Original equipment manufacturers, such as Volkswagen AG; and

  • Public sources, e.g. social media (when available).

5 – Disclosure of your personal information

Your personal information may be disclosed to the following parties (where you have provided your consent):

  • Dealerships/workshops so that they can provide you with services you have requested, such as providing technical assistance, booking services and providing quotes for repairs. Your preferred authorised dealership can access service data including (but not limited to), error codes, technical data such as odometer readings, battery voltage and warning lamps and engine status;

  • Volkswagen Assist in the event of a breakdown;

  • Affiliated group companies of VGA;

  • Suppliers and dealers, including IT support and our third party service providers so that they may provide services for us or on our behalf;

  • Public authorities, for the purpose of complying with legal obligations and/or safeguarding public interests; and

  • Partners who wish to provide an independent service for you. This will only take place if you have given your consent beforehand in the App or if you have consented to the relevant partner to obtain your personal information from us.

Your personal information may be transferred outside of Australia.

Connected Cars, which operates the App and the associated platform used by VGA, dealerships,and fleet managers, is located in Denmark. Connected Cars provides VGA with high level technical data insights, however this data is anonymised and aggregated (i.e. does not include personal information). In other words, it is not personally-identifiable.

Overseas recipients are likely to be:

  • Google LLC., including Google Suite, Google Cloud and Google Analytics in the EU. All data is stored in the Google Cloud Platform in Sydney, Australia.

  • Spotler, in the Netherlands, a provider of a digital mail service..

  • Intercom, in Ireland, a provider of a customer support ticket-system and customer support.

  • CustomerGauge, in the Netherlands, a provider of customer satisfaction surveys.

  • Volkswagen AG, located in Wolfsburg, Germany, which is VGA’s parent company.

6 – Access and correction requests

You have a right to access and correct your personal information, subject to some exceptions allowed by law. If you would like to access and request the correction of information we hold about you, you can do so by contacting us in any of the ways set out at the bottom of this Privacy Policy. You may be required to put your request in writing for security reasons and, in some circumstances, we may need to charge an administrative fee to recover the reasonable costs incurred in responding to your access request. This administrative charge is only designed to help us reasonably recover the costs associated with providing you with access and does not apply to the making of the request or correction requests. Before we act on a request, we will provide an estimate of the access fee and ask you to agree to it. 

We will confirm receipt and endeavour to respond to the privacy access or correction request by no later than 30 days’ from the date that the request was received. We will take all reasonable steps to correct information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. This includes correcting personal information that has been disclosed previously to a third party (unless it impracticable or unlawful to do so).

Your access or correction request may be refused in a number of circumstances, such as where the information relates to anticipated legal proceedings or if the request for access is frivolous or vexatious. If we deny or restrict your access or correction request, we will write to you to let you know why, unless, having regard to the grounds for the refusal, it would be unreasonable for us to do so within 30 days’ from the date that the request was received.

If we refuse your correction request, we will include a statement with your personal information about the requested correction, if you ask us to do so. You may make a complaint about a refusal to the Office of the Australian Information Commissioner (“OAIC”).

7 – Making a complaint

If you believe that your privacy has been compromised, or if you feel that we have breached privacy laws, you are entitled to make a complaint. Complaints can be made by contacting us using our contact details in the “How to contact us” section of this Privacy Policy.  

You will need to provide us with details of your complaint and any supporting evidence and/or information. You will receive an acknowledgement from us no later than 7 business days after receipt of your written complaint.

We will investigate your compliant in accordance with our internal complaints resolution process and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you. You will be sent the final decision in writing no later than 20 business days after you contact us, if we have all the necessary information to make that decision. When this is not possible, we will contact you and let you know how long it will take for us to resolve your complaint.

If you disagree with our decision, you may refer your complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or emailing enquiries@oaic.gov.au.

8 – How to contact us

If you wish to notify us of your new contact details, update your personal information, opt out of direct marketing, make a complaint about a breach of privacy, wish to access your personal information that we hold or have any questions in relation to the accuracy of your information or privacy, please contact our Privacy Officer by:

Telephone

1800 060 936   
8:30 am – 5:00 pm (AEST) Monday to Friday (excluding NSW Public Holidays)

Email

privacy@volkswagen.com.au

Mail

Privacy Officer
Volkswagen
Locked Bag 5333, Botany NSW 1455

Please include the identification number of your vehicle (VIN) in all correspondence. This number is 17 characters long and can normally be found on your registration documents.

9 - Changes

We may update this Privacy Policy from time to time. In the event of any significant changes to the Privacy Policy, you will receive reasonable notice of the changes before the changes take effect by email or by a push notification through the App.

Latest update: May 6th, 2024