Privacy Policy

Volkswagen Group Services, Unipessoal, Lda (hereinafter also abbreviated to its acronym, “VWGS”), having registered offices at Quinta da Marquesa, 2954-024 Quinta do Anjo, legal person 507184181, has sought to forge solid and lasting relationships with its customers and partners based on transparency and trust.

This Privacy Policy describes who we are, for what purposes we use your personal data, how we process and store it, with whom we share it, how long we keep it, as well as how to contact us and exercise your rights.

 

Controller

Your personal data will be processed by VWGS as joint controllers, in the sense that such expressions are defined by the General Data Protection Regulation (“GDPR”).

 

Why do we process your information?

VWGS processes your data for the following purposes:

  1. Recruitment and selection of employees, conclusion and performance of contracts or associated steps prior to entering into a contract, based on the fulfilment of legal and/or contractual obligations;
  2. institutional communication, management of customer or supplier complaints, provision of information on the activities carried out and services provided by VWGS, based on its legitimate interest in improving and rendering more effective the services provided.

Where applicable, VWGS may request your consent to process your personal data for specific, explicit and legitimate purposes.

 

Sharing and transfer of personal data

VWGS shares data with third parties, namely Courts, the Tax and Customs Authorities and Social Security, among others, in accordance with the law and under the duty of cooperation.

VWGS also transmits your data to customers under the ambit of recruitment and selection services.

VWGS also transfers the data to service providers acting as subcontractors solely in the name of and on behalf of VWGS under its guidance or support, and which comply with technical and organisational measures equivalent to those to which they are bound.

 

How long do we retain your information?

VWGS only retains personal data for the period necessary to fulfil the purposes for which they were collected. The retention periods for most of the personal data processed by VWGS result from the law, regulations governing VWGS’ activities, or contracts concluded with customers, suppliers and partners.

After the period necessary for the pursuance of the purposes of the processing of data by VWGS, the data will be permanently deleted or anonymised.

 

Exercising the Rights of Data Subjects

At any time you may:

 

  • Request access to information – you are entitled to obtain confirmation that the data concerning you have or have not been processed and, where appropriate, to access your personal data and to access the information provided for in law.
  • Request the correction of information if inaccurate or incomplete – you may at any time ask VWGS to correct inaccurate or incomplete data concerning you.
  •  Request the deletion of your personal data – you may ask VWGS to delete your data, without undue delay, and the latter is under an obligation to delete your personal data, without undue delay, inter alia, for one of the following reasons:
  1.  The personal data are no longer necessary for the purpose that gave rise to their collection or processing;
  2. You object to their processing, and there are no prevailing legitimate interests justifying their processing; or
  3. You have withdrawn your consent concerning the processing of the data (where the processing is based on consent), and there is no other grounds for the aforementioned processing.
  • Request restriction of processing of your personal data – you are entitled to ask VWGS to restrict the processing of your personal data if, inter alia, one of the following situations applies:
  1. You contest the accuracy of the personal data, for a period that allows VWGS to verify its accuracy;
  2. The processing of the data is lawful and you object to the deletion of the personal data, instead requesting restrictions on their use;
  3. VWGS no longer requires the personal data for processing purposes, but such data are required by you for the purpose of declaring, exercising or defending a right in legal proceedings;
  4. If you have objected to processing, until it is found that the legitimate reasons of the data controller prevail over those of the data subject.
  •  Objecting to the processing of your personal data – you may object to the processing of your personal data in cases where the data is processed based on the legitimate interests pursued by VWGS. In this situation, we may demonstrate the existence of legitimate grounds that prevail over your legitimate interests.

 

You may at any time exercise any of the above rights via email using the address dpo@volkswagen-groupservices.com or via letter addressed to the Data Protection Officer, sent to the postal address Quinta da Marquesa, 2954-024, Quinta do Anjo.

If you have questions or complaints, you may also contact the Data Protection Officer using the email address dpo@volkswagen-groupservices.com.

Alternatively, you may choose to contact the Supervisory Authority, which, in Portugal, is the National Data Protection Commission, by sending your message to geral@cnpd.pt.

 

Information Security

VWGS implements and ensures the maintenance of adequate safeguards so that its internal procedures geared towards the security of personal data comply with applicable regulations. VWGS also makes every effort to ensure that the contracts concluded with the third parties with whom it collaborates, as partners or service providers, ensure adequate protection of the personal data to which they have access. VWGS limits access to personal data to specific employees, and only where their contact with such personal data is warranted within the scope of their duties.

VWGS takes the necessary steps to ensure the secure processing of personal data. In particular, it takes precautionary measures to protect personal data from loss or misuse, and uses security procedures to prevent unauthorised access to those personal data.

Changes to the Privacy Policy

VWGS may update this privacy policy should changes be made to the manner in which personal data are processed. VWGS reserves the right to make changes to its practices and this Policy at any time; please check back regularly for updates or changes to our Privacy Policy.

 

Version 2.0 | 17 December 2019