Privacy Policy

It is important to Volkswagen Group Singapore (“Volkswagen Group Singapore”) that your personal data is collected and processed securely and lawfully.

This privacy policy (“Privacy Policy”) describes how we collect and process your personal data. 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 the GoConnect App.

“You” means the owner and/or the primary user of the vehicle in which the CC-Link is installed or additional users as the primary user invites to the App. The CC-Link is the physical hardware, connected to the OBD port, collecting and transmitting data from the vehicle to Volkswagen Group Singapore.

1 - Description of the processing

We may (with your prior consent) where required by applicable laws such as the Singapore Personal Data Protection Act (“applicable laws”), process your personal data as follows:

1.1 - Creating a user account and general use of the App

Activating your vehicle, the CC-link installed in your vehicle and creating a user, enables you to use the App and enables us to communicate with you about the App.

1.2 - Categories of personal data

We process the following personal data about you:

A. General personal data:

Name, Address, Email address, Telephone number
Your preferred workshop
Master data about the registered vehicle, including its brand, year, model and VIN
Technical data about the registered vehicle, including information about the vehicle's equipment and configuration
Meta-data about the service on the registered vehicle, including information related to time and completion of requests. Data from workshop bookings if available in the your country
Verification of ownership, i.e. documentation from national vehicle registration offices.
Use of the chat function in the App, including questions sent to your preferred workshop.
Data from your use of the App. Please see our Privacy Policy
Data from the CC-link, please see table showing services and data points

The provision of your personal data is voluntary. That said, we might not be able to provide you with some of our services if you choose not to provide us with certain requested information as identified in our App.

1.3 - Purpose

We process your personal data for the following purposes, where the references in the parenthesis refers to the categories of personal data:

Creation of your user profile and account. (A.a)
General management of your account and provision of a service requested by you. (A.a, A.b and A.f)
General support regarding your use of the App (A.a - A.i)
Analyze 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”) (A.c, A.d, A.e and A.i)
Sending you service announcements, notices and other changes to the App or Terms of Use. (A.a, A.d, A.e and A.i)
Preparation of statistics concerning our services and further development of our services. (A.h)
Business-, process- and product development, optimization of customer functionality and elimination of product defects related to our services, in connection with the dealers, workshops, importer and OEM (A.e)
Marketing (A.a, A.b and A.e)

1.4 - Sources

We collect information from the following sources:

Directly from you
Directly from the vehicle via the CC-link
Dealerships/workshops
Importers/OEMs
The national vehicle registration offices (when available).

1.5 - Legal basis for processing

The purpose of this Privacy Policy is to detail our approach to protection of your Personal Data and to ensure the consistent handling of Personal Data and the compliance with the provisions of the Singapore Personal Data Protection Act 2012 and its regulations ("PDPA").

1.6 - Recipients

We share the personal data with the following parties:

Dealerships/workshops
Importers/OEMs
Affiliated group companies
Suppliers and dealers, including IT support and data storage providers
Public authorities (whether local or overseas), for the purpose of complying with legal obligations and/or safeguarding public interests, which supersede the interests of secrecy
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.
Service providers such as professional advisors and accountants
Third parties in connection with a potential or actual sale of our company or any of our assets, or those of any affiliated or associated company, in which case personal data held by us may be one of the transferred assets.

We may share aggregate, anonymized, or de-identified information about users with third parties for marketing, research or similar purposes.

1.7 - Security and Retention

We take appropriate technical, physical and organisational measures to ensure that your personal data is secured against unauthorised or accidental access, processing, erasure, loss or use.

We will keep Personal Data only as long as the purpose for which your personal data was collected is still being served and the retention is still necessary for legal or business purposes ("Purposes"). We will take all reasonable steps to ensure that all Personal Data is destroyed, permanently deleted or anonymised if it is no longer required for those Purposes.

2 - Joint data responsibility

Volkswagen Group Singapores has company profiles and pages on “Social media”, “SoMe” platforms and as such we are joint data controllers with the below mentioned SoMe platform providers for the processing of personal data solely pertaining to the initial collection of personal data on our company profiles or page on the SoMe platforms.

Volkswagen Group Singapore’s complies with the Singapore Data Protection Act (PDPA) and strives to ensure that you receive adequate information about the processing of your personal data when visiting Volkswagen Group Singapore’s profiles or pages on SoMe platforms.

Facebook (Meta Platforms, inc.)
Facebook’s privacy policy is available here.
You can adjust your privacy settings on Facebook here.

LinkedIn (LinkedIn Ireland Unlimited Company)
LinkedIn’s privacy policy is available here.
You can customize your privacy settings on LinkedIn here.

2.1 - Purpose

We process your personal data for the following purposes:

Improving our services and marketing, including our SoMe profiles and pages. We may use your personal data to let you know about our products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. We will obtain your consent prior to sending you marketing materials (as required by applicable law). You may ask for us to stop direct marketing at any time. You may use the “unsubscribe” link found in email communications, or alternatively you can contact us using the contact details below.
To communicate with you if you comment on a post, leave a review or send us a message. Please note that Volkswagen Group Singapore has chosen to limit its use of SoMe platforms to only receive simple inquiries that contain minimal information. This is implemented by encouraging our visitors on the SoMe platforms to refrain from sending private information to us. Instead, we direct them to customercare@vw.com.sg for such purposes.

2.2 - Categories of personal data

We process the following personal data about you:

Information available on your profile.
Any communication you have with us through our pages or profiles, such as questions and comments on our posts.
IP address.

2.3 - Sources

We collect information from the following sources:

Directly from you.
Public sources, e.g. social media.

2.4 - Legal basis for processing

We process personal data on the following legal basis:

PDPA art. 14. Consent (required by the Singapore Personal Data Protection Act).
PDPA art. 21 Our legitimate interest in being able to efficiently communicate and market our services to you.

2.5 - Recipients

We share the personal data with the following parties:

Dealerships/workshops
Affiliated group companies.
Suppliers and dealers, including IT support

The SoMe platforms may, among other things, share your personal data with the following categories of recipients:

Other entities in the group of companies of which the SoMe platform is a part.
External partners providing analysis and survey services.
Advertisers.
Other individuals who visit our profile or page (to the extent your information is publicly available).
Scientists and other academics.

You can find more information about sharing of your personal data in the privacy policy of the respective SoMe platform provider.

SoMe platform providers may transfer your personal data to recipients outside Singapore in accordance with applicable data protection legislation. You can read more in the respective privacy policies.

2.6 - Security and Retention

We take appropriate technical, physical and organisational measures to ensure that your personal data is secured against unauthorised or accidental access, processing, erasure, loss or use.

We process the personal data as long as it is deemed necessary for the purposes stated.

We will retain personal data for as long as necessary for the purposes mentioned.

2.7 - Your rights

As the SoMe platform providers are functionally able to take the necessary steps to meet your requests regarding your PDPA rights or other rights under applicable laws, we encourage you to contact the respective SoMe platform providers. However, if you believe that Volkswagen Group Singapore can meet your request better than the social media providers, then please contact us via pdpa@vw.com.sg.

3 - Consequences of processing

By means of the processing activities described, we can gain detailed insight into the use and general condition of your vehicle.

It is important to be aware that some of the services offered require the collection of a vast amount of data from the vehicle through which a picture of your use of the vehicle can be built. The “my trips” function will provide a detailed overview of the use of the vehicle in terms of time and place, speed and fuel consumption as a derived consequence of the detailed data collection. Further, the patterns identified in the technical data from the vehicle, e.g. error codes, may potentially reveal particular usage patterns of the vehicle, e.g. gps location, time of use and driving patterns with particularly heavy loads causing excessive strain on the vehicle.

5 - Transfers to countries outside the EU/EEA or Singapore

Some of the Third Parties with whom we share personal information, may be located outside the EU and the EEA, and the country in which you are based. Thus, transfer of your personal data from your country of residence to third countries may be involved. For example:

Google LLC., including Google Suite, Google Cloud and Google Analytics. Please see list of locations from which Google may process your personal data here: Google datacenter locations.

In some cases, the country is approved by the European Commission as a so-called “Safe Third Country”, otherwise the transfer takes place on the basis of the EU Commission’s standard contractual clauses or the EU-U.S Data Privacy Framework approved by the European Commission. In all overseas transfers, we will ensure that the data recipient and the jurisdiction to which personal data is transferred to has in place comparable measures to that required under the applicable laws of the transferor’s country.

6 - Your rights

You have the following rights (these rights may vary depending on the jurisdiction in which you are using our services):

You have the right to request access to, rectification of or erasure of your personal data.
You have the right to object to the processing of your personal data and to have the processing of your personal data restricted.
In particular, you have a right to withdraw your consent where you have provided consent and/or an absolute right to object to the processing of your personal data for direct marketing purposes.
If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Such withdrawal shall not affect the lawfulness of the processing carried out prior to the withdrawal of your consent.
You have the right to receive the personal data provided by you in a structured, commonly used and machine-readable format (data portability).
You have the right to lodge a complaint with the Singapore Personal Data Protection Commission or other equivalent authority at any time.
If you wish to exercise your rights, please contact us via pdpa@vw.com.sg.

These rights may be subject to conditions or restrictions. Accordingly, you may not have a right to data portability in certain cases depending on the circumstances of the processing activities.

7 - Changes

In the event of any significant changes to the Privacy Policy, you will receive an email or be notified by push message through the App. We will also seek your consent to those changes, where required by applicable law.

Latest update: 10th May, 2024