VWPI Limited (trading as VW Parts International)(hereinafter “VWPI”) collects, uses and protects your personal data with reasonable diligence according to the strict data protection provisions in the UK and in compliance with the provisions of the European General Data Protection Regulation (hereinafter “GDPR”).
“Personal Data” means any information relating to an identified or identifiable natural person (hereinafter “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (hereinafter “Personal Data”).
“Non-Personal Data” is data which will be logged for internal system-related and statistical purposes, which cannot be tracked back to you (name of the file accessed, date and time of access, data volume transferred, notification of successful access and transfer, web browser and requesting domain). Data disclosing your identity will not be publicly used by VWPI. VWPI may, however, use any data collected in anonymized form, in particular for purposes of statistical analyses.
in anonymized form, in particular for purposes of statistical analyses. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Pseudonymisation” means the processing of personal data in such manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Filing System” means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with the laws of the European Union or any of its Member States shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
“Third party” means a natural or legal person, public authority, agency or body other than the Data Subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorised to process personal data.
2.12. “Consent” of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
3. Processed Data
The following Personal Data of the Data Subject will be collected, saved and processed by the Controller:
- full name (first and last name)
- e-mail address(es)
- billing and shipping address(es)
- Telephone number
- Payment method
The following Personal Data of the Data Subject might be collected, saved and processed by the Controller as necessary in order to process your order:
- title, salutation
- credit card details
- id / tax reference if required for customs purposes
The following Non-Personal Data of the Data Subject will be collected, saved and processed by the Controller:
- IP address;
- date, time and duration of file access;
- names of products/pages viewed by the Data Subject;
- web browser used;
- Geographical location
- Items added to parts list
4. Processing of Personal Data
VWPI may collect, store and use your Personal Data when you register on the VWPI website or other online platforms which interact such as eBay (hereinafter “Website”), as well as when you fill out an offline form or provide data to VWPI in any other form of interaction.
- administer the Website and its business (e.g. your registered account);
- process your order with the appropriate shipping ompany
- enable your use of the services available on the Website;
- supply to you services purchased through the Website;
- send to you email notifications that you have specifically requested;
- send to you our email newsletters in respect of the e-Privacy-Regulation respectively in case you have accepted such service, (you can inform us at any time if you want to unsubscribe from the newsletters);
- keep the Website secure and prevent fraud;
- verify compliance with the terms and conditions governing the use of the Website.
VWPI will not, without your express consent, supply your Personal Data to any third party for marketing purposes, whether directly or indirectly.
5. Conditions for consent
Where processing is based on consent according to paragraph 4.2, the Data Subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the Data Subject shall be informed thereof.
6. Rights of the Data Subject
The Data Subject shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the Data Subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the Data Subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in paragraph 6.8.1 and 6.8.2 and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject.
Where personal data are transferred to a Non-EU-Member State or to an international organisation, the Data Subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
The Controller shall provide a copy of the Personal Data undergoing processing. For any further copies requested by the Data Subject, the Controller may charge a reasonable fee based on administrative costs. Where the Data Subject makes the request by electronic means, and unless otherwise requested by the Data Subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy referred to in paragraph 6.1.3 shall not adversely affect the rights and freedoms of others.
6.2. Right to Rectification
The Data Subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
6.3. Right to Erasure (“Right to be forgotten”)
The Data Subject shall have the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the Data Subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing;
- the Data Subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing pursuant to Article 21(2) GDPR;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
Where the Controller has made the Personal Data public and is obliged pursuant to paragraph 6.3.2 to erase the Personal Data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Controllers which are processing the Personal Data that the Data Subject has requested the erasure by such Controllers of any links to, or copy or replication of, those Personal Data.
Paragraphs 6.3.1 and 6.3.2 shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) GDPR as well as Article 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 6.3.1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
6.4.Right to restriction of processing
The Data Subject shall have the right to obtain from the Controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the Data Subject, for a period enabling the Controller to verify the accuracy of the personal data;
- the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the Controller no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
- the Data Subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the Controller override those of the Data Subject.
Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A Data Subject who has obtained restriction of processing pursuant to paragraph 6.4.1 shall be informed by the Controller before the restriction of processing is lifted.
6.5. Notification obligation regarding rectification or erasure of personal data or restriction of processing
The Controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with paragraph 6.2, paragraph 6.3.1 and paragraph 6.4 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller shall inform the Data Subject about those recipients if the Data Subject requests it.
6.6. Right to data portability
The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided, where:
- the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) GDPR or on a contract pursuant to point (b) of Article 6(1) GDPR; and
- the processing is carried out by automated means.
In exercising his or her right to data portability pursuant to paragraph 1, the Data Subject shall have the right to have the personal data transmitted directly from one Controller to another, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
The right referred to in paragraph 6.6.1 shall not adversely affect the rights and freedoms of others.
6.7. Right to object
The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
At the latest at the time of the first communication with the Data Subject, the right referred to in paragraphs 6.7.1 and 6.7.2 shall be explicitly brought to the attention of the Data Subject and shall be presented clearly and separately from any other information.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the Data Subject may exercise his or her right to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, the Data Subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.8. Automated individual decision-making, including profiling
The Data Subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
Paragraph 6.8.1 shall not apply if the decision:
- is necessary for entering into, or performance of, a contract between the Data Subject and the Controller;
- is authorised by the law of the European Union or any of its Member States to which the Controller is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests; or
- is based on the Data Subject’s explicit consent.
In the cases referred to in points (a) and (c) of paragraph 6.8.2, the data Controller shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision.
Decisions referred to in paragraph 6.8.2 shall not be based on special categories of personal data referred to in Article 9(1) GDPR, unless point (a) or (g) of Article 9(2) GDPR applies and suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests are in place.
7. Links to other websites
Cookies are used on the Website for the following purposes:
- To remember that you are logged in and that your session is secure.
- To remember your progress in services we provide (e.g. basket contents, parts lists).
- To remember the content of your shopping cart.
- To track the pages you visit via Google Analytics.
Last update: 22nd May 2018
VWPI Limited (VW Parts International)