Data Protection Statement

 

Data Protection Statement

Porsche Connect website, Porsche Connect store, Porsche Connect portal, and Porsche Connect services

We, Porsche Connect GmbH (hereinafter "we" or "PC GmbH"), are pleased by your visit to our website and by your interest in our business and our products. Protecting your privacy while processing data is important to us. We are very serious about protecting your personal data and treating it as confidential. Your data are collected and used exclusively in accordance with the statutory provisions of the data protection laws of the Federal Republic of Germany. This Data Protection Statement serves to inform you about the personal data that we collect, process, and use in connection with your use of our Porsche Connect website, our Porsche Connect portal, our Porsche Connect shop, and the Porsche Connect services (hereinafter collectively the “Porsche Connect infrastructure”), and for what purpose this is done..

 

1. Data controllers

The responsible entity for purposes of the data protection laws (data controller) is:

Porsche Connect GmbH

Porscheplatz 1

70435 Stuttgart

Any questions or suggestions relating to data protection can also be sent to us by e-mail to connect@uk.porsche.com.

 

2. Subject of data protection

The subject matter of data protection is personal data. According to Section 3 (1) of the German Federal Data Protection Act [Bundesdatenschutzgesetz (BDSG)], personal data comprises the particulars of the personal or material circumstances of an identified or identifiable natural person. This includes, for example, information such as names, postal mailing addresses, e-mail addresses, or phone numbers, but also usage data. Usage data are information that necessarily arises during and through the use of our Porsche Connect website, our Porsche Connect portal, our Porsche Connect shop, and the Porsche Connect services, such as, for example, information about the start, end, and extent of any usage of our website, as well as login data.

 

3. Use of our website: collection and use of your data

Data are or can be collected even if you use our website without registering. The following is an overview of the various ways in which data are collected, processed, and used, as well as the purposes for doing so.

3.1 Automated data collection

When you access our website, your Internet browser automatically transmits data for technical reasons. The following data are stored separately from other data that you might transmit to us:

• date and time of access;

• length of the visit to our website;

• type of web browser/web browser version;

• operating system used;

• the pages on our site that you visit;

• amount of data sent;

• type of event.

These data are stored to ensure technical operations and information security, and they are attributed to a specific person only as warranted.

3.2 Cookies

We store “cookies” so that we can offer you a comprehensive functionality and make the use of our website more convenient. Cookies are small files that are stored on your computer by your Internet browser. If you do not want cookies to be used, you can block the storing of cookies on your computer by changing your browser settings. Please note that this could limit the functionality and functional scope of our offerings.

3.3 Google Analytics

PC GmbH uses Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics utilizes “cookies,” i.e., text files that are stored on your computer and that make it possible to analyse your use of the website. The information generated by cookies about your use of this website (including your abbreviated IP address) is transmitted to a Google server in the United States and stored there. Google will use this information to analyse your use of the website, compile reports on website activities for us, and provide other services relating to website and Internet use. Google will also provide this information to third parties where appropriate, or if prescribed by law, or if third parties process that data on Google’s behalf. More information about how Google Analytics uses your data can be found here:

https://www.google.com/policies/privacy/partners/

If you do not want any website analysis, you can deactivate Google Analytics by means of a browser add-on, which you can download here:

http://tools.google.com/dlpage/gaoptout?hl=en-GB

 

4. Use of the Porsche Connect services: collection and use of your data

When you register with and use the Porsche Connect store and the Porsche Connect portal, when you request and use online services, and when you use Porsche Connect services and the Porsche Connect infrastructure, personal data will be collected, processed, and used through the Porsche infrastructure and, where appropriate, provided to third parties, as follows:

4.1 Registration process

In order to use the Porsche Connect services, you must register on the Porsche infrastructure. You have a choice between two ways of registering:

1. Registration through authorized dealers:

If you choose this option, your authorized dealer uses its access to our systems to enter the data that you have given to it. You will then receive a link by e-mail, asking you to confirm your registration. Please note that authorized dealers are independent entities and that we have no control over them. You will also verify your registration through a second feature, e.g., an SMS code that you enter in the Porsche Connect portal.

2. Self-registration:

If you have not registered through an authorized dealer, you can enter your data in the Porsche Connect portal on your own. After entering your vehicle identification number, you will also upload a copy of an identification document and proof of ownership, as well as— if you are not the vehicle owner—a power of attorney from the vehicle owner. These documents are reviewed in accordance with our verification criteria and are then deleted after verification is completed. If the review is successful, you will receive a link by e-mail, asking you to confirm your registration. You will also verify your registration through a second feature, e.g., an SMS code that you then enter in the Porsche Connect portal.

(a) Data required for registration

When you register on the Porsche Connect infrastructure, you must enter your Porsche ID, access data, name and name extensions, contact and address data, mobile phone number, e-mail address, and the language in which you would like to communicate with us (if applicable) in the case of self-registration; with registration through an authorized dealer, you must verify such information. These data are needed to set up and manage a user account for you so that you can take advantage of the full range of Connected Car services. We also need this information, and possibly other data, in order to react to requests, questions, and criticism.

We also store the time of your most recent login.

During registration, we will review your address data by means of a plausibility check..

(b) Optional data when registering

During registration, you will also have the opportunity to provide other optional information, such as additional name information (e.g., academic titles), business contact data, date of birth, other phone numbers, credit card information (which is stored exclusively with the payment service provider), and your vehicle license number and a personal vehicle name. Please note that such information is not required for registration and that you alone decide whether to give us these data.

4.2 Porsche Connect infrastructure: data processing after registration

In the Porsche Connect infrastructure, an authorized dealer from our Porsche Partner network is assigned to you in accordance with the above Declaration of Consent. If you self-register, you can choose the preferred authorized dealer. That dealer can access your data stored at Porsche Connect in order to, for example, provide individualized support tailored to your interests, conduct surveys about your satisfaction, or provide you with information about vehicles or vehicle-specific services.

4.3 Requesting Porsche Connect services

The infotainment system integrated into your vehicle (Porsche Communication Management, or PCM for short) is connected to the Porsche Connect infrastructure and enables you to use the Porsche Connect services that you request through our Porsche Connect store, and to use third-party services that you request through your smartphone independently of our offerings.

We collect and process your personal data only to the extent necessary to enable the use of the respective Porsche Connect service.

Before you can use the Porsche Connect services that you have purchased in the Porsche Connect store or Porsche Connect services that are operated and/or provided by us, the system built into your Porsche will perform an authorization check to verify whether you have signed up for the services in question. General information about the collection and use of personal data when you use online services for which you have signed up through us is presented in section 4.4, and details can be found in the descriptions of the various services.

4.4 Use of Porsche Connect services

You can use the requested Porsche Connect services through the infotainment system (PCM) in your vehicle. The infotainment system connects to the Porsche Connect infrastructure for that purpose.

If you use the online services for which you have signed up through the Porsche Connect store in your vehicle or on other devices, we will process the following of your personal data for the purpose of enabling the use of the online services and for support purposes: vehicle identification number, an encrypted number that is generated from the Porsche ID, and information on the frequency, duration, and time of use.

When you use the individual Porsche Connect services, the following categories of personal data will also be processed, depending on the specific functions of the respective Porsche Connect service:

a. Authorization information, which shows that the vehicle or the device is enabled for the respective Porsche Connect service and which can be linked to your registration data from the Porsche Connect infrastructure.

b. Login information, which is needed if you want to use services of other providers in your vehicle or on other devices where a login is required.

c. Communication information, which is necessary to establish a connection between your vehicle and/or other devices and our servers or the servers of third-party providers of content for Porsche Connect services.

d. Location and movement information, which is necessary in order to display location-related content in the vehicle.

e. Voice data, which enables voice commands and voice input in certain Porsche Connect services. Voice data are transmitted to us from the vehicle or device as a recording so that they can be converted into text. The text that is then generated by a service provider is transmitted back to the vehicle, and we then delete the recording.

f. Contact data, which is used in communication services such as sending e-mail or SMS text messages.

g. Other content that must be exchanged with us or with service providers so that services can be provided to you .

Depending on the type of the wireless network connection, the data exchange can be terminated by removing the SIM card or disengaging your device. Detailed information about what data are collected and processed in connection with a specific online service is available in the respective descriptions of online services at www.porsche.com/connect.

4.5 Use of a third-party provider’s services

If you use any services of third-party providers that you cannot request through our Porsche Connect portal, the content of such services may be displayed in your vehicle, and information may be exchanged between your vehicle and the service provider. If you link a mobile device, content is mirrored only on the PCM in your vehicle. We do not access these services of third-party providers, and we receive no notice of any content. Therefore, please review the third-party provider's respective data protection information.

When you use such third-party services, it is possible that personal data will also be used beyond the extent necessary to provide the service and for the service to function properly.

We have no control over the processing of data by these third-party providers or over the location of the data processing. Therefore, please inquire with the respective third-party providers concerning the nature, extent, and purpose of the collection and use of personal data with regard to the respective online service.

4.6 Sharing of data

We use a payment service provider to process payments for paid services related to our Porsche Connect services. For the processing of payments, we direct you to the payment service provider’s system. You enter your credit card information directly into those systems for the purpose of payment processing. We do not store any of your credit card information.

We share your personal data with third parties only if that is necessary in order to provide the respective Porsche Connect service, or if there is statutory authorization for doing so, or if you have consented to this.

We occasionally rely on contractually affiliated group companies of Porsche AG, outside companies, or external service providers for the provision of services, for example in the areas of technical infrastructure and maintenance for the offerings of Porsche Connect services, the transmission of advertising (only if you have expressly consented to this), customer service, and payment processing. In such cases, information is provided to these companies or individual persons to enable further action. These external service providers are chosen by us with care and are reviewed on a regular basis in order to ensure that your privacy is preserved. The service providers are permitted to use the data exclusively for the purposes specified by us. If individual functions within the Porsche Connect services are performed on our behalf by service providers whose registered office or data processing location is not situated in a member state of the European Union or in another party to the Agreement on the European Economic Area, we will ensure that the statutory requirements concerning data processing in third countries are complied with..

4.7 Support through the Contact Centre

You can get support in using the Porsche Connect infrastructure through our Contact Centre. For example, you can use our phone Contact Centre to request changes in your personal customer data or to request online services and any other services. In order to do so, you must give the Contact Centre your Porsche ID. After you have identified yourself by providing your Porsche ID or other security details, the Contact Centre will directly access your user account and make the requested changes or perform the requested activities on your behalf. The Contact Centre staff takes only those actions that you explicitly request.

4.8 Use of online services by unregistered drivers

If other persons use your vehicle and the infotainment system (PCM), the data specified in section 4.4 are collected. If the other person does not have their own user account, this information is collected and stored only under your user account. In this case, it is not possible for us to identify this other driver due to the lack of identifying information.

 

5. Deletion of your data

If you delete your Porsche Connect user account, your online profile will be deleted. Any data that must be retained for legal reasons are blocked. In that case, the data are no longer available for further use.

 

6. Right of disclosure and correction

You have the right to request disclosure of your personal data that we store. You also have the right to correct inaccurate data and to block and delete your data, except where that is not possible due to statutory retention obligations. If you have questions about the collection, processing, or use of your personal data and about correcting, blocking, or deleting that data or revoking previously granted consents, you can also contact us free of charge. Please write us at connect@uk.porsche.com or by mail at the address stated above.

 

7. Data security

We take all necessary state-of-the-art technical and organizational measures to secure your personal data against loss, falsification, and disclosure to unauthorized persons..

 

8. Links to other websites

Websites of other providers that are linked to from this website have been and are designed and provided by third parties. We have no control over the design, content, and function of these linked websites. We expressly distance ourselves from any and all content in all linked websites. Please note that the third-party websites linked to from this website might install their own cookies on your device and/or collect personal data. We have no control over this. Therefore, please make any inquiries about this directly with the providers of these linked websites.

 

9. Connectivity (your vehicle’s wireless network connection)

This Annex to the Data Protection Statement of Porsche Connect GmbH describes the data-processing processes and the data exchange with third parties in connection with establishing a wireless network connection for your vehicle (“connectivity”).

Depending on the features of your vehicle, connectivity can be established by dialing into the vehicle interfaces via a Wi-Fi connection provided by an external device or via the wireless network module of your vehicle’s PCM. Depending on the features of your vehicle, the wireless network module of your vehicle’s PCM may have an installed insertable SIM card or a permanently installed SIM card.

9.1 Definitions

(a) SIM card providers

The SIM cards used to establish connectivity are provided by mobile network operators that provide telecommunication services (“SIM card providers”). Depending on the features of your vehicle, these SIM card providers vary.

(b) Installed insertable SIM card

Depending on the features of your vehicle, you can establish connectivity in your vehicle yourself by way of a SIM card that you install in the vehicle and that you have received from your respective SIM card provider (“installed insertable SIM card”). Your respective SIM card provider is responsible for your own installed insertable SIM card and the data-processing processes associated with it. Please contact your respective SIM card provider for information on the nature, extent, and purpose of the collection, processing, and use of data and on data security during signal transmission.

(c) Permanently installed SIM card

Depending on the features of your vehicle, connectivity can be established by a SIM card that has already been installed directly in your vehicle by the manufacturer and that is not replaceable (“permanently installed SIM card”). A permanently installed SIM card cannot be removed manually to stop connectivity. For information on responsibilities for the data-processing processes in connection with the permanently installed SIM card, please see Sec. 3 below.

(d) Network operator and virtual network operator

The (telecommunication) “network operator” operates a telecommunication network and provides the respective participants with access to this network. The “virtual network operator” puts together individual network solutions based on the infrastructures and technologies of various network operators without possessing a network infrastructure of its own. SIM card providers can be identical to network operators, but this does not necessarily have to be the case.

9.2 Data storage during vehicle production

If your Porsche vehicle is equipped with a permanently installed SIM card, we store the SIM card numbers (ICCID, IMSI, MSISDN) that we receive with the SIM card from the SIM card provider, in conjunction with the respective device and vehicle identification number, during the vehicle production process.

This data storage takes place for the purpose of managing SIM card numbers and to match the vehicle with a SIM card number in the event that government agencies request information from Porsche Connect GmbH.

9.3 Data exchange in the case of permanently installed SIM cards

General information

Wireless network modules in Porsche vehicles with permanently installed SIM cards that are active dial in, where available, to wireless networks of the respective network operator – regardless of whether you are registered for Porsche Connect or have requested Porsche Connect services. Telecommunication data (data collected, processed, and used based on the provision of the telecommunication service or to establish connectivity) may be exchanged for the purpose of the wireless network connection or to establish connectivity and, where applicable, to perform the relevant online functions of the Porsche Connect services you have requested in your vehicle via the wireless networks of the respective network operator, e.g. with wireless cells.

Within the scope of the wireless network connection, it is not impossible that when signals are transmitted via public telecommunication networks outside your vehicle, third parties, especially network operators, can access certain information and potentially determine your location. In addition to the respective network operator, virtual network operators may also have access to this information in the process.

Provision of connectivity via permanently installed SIM cards takes place through the following virtual network operator:

• CUBIC Telecom, Cubic Telecom Limited, Corrig Court, Corrig Rd, Sandyford Industrial Estate, Dublin 18, Ireland.

Please contact the virtual network operator for information on the nature, extent, and purpose of the collection, processing, and use of data and on data security during signal transmission.

9.4. Data processing within the scope of telecommunication services

We collect, process, and use your inventory data (such as your name, address, and date of birth) that are collected during registration in the Porsche Connect portal or Porsche Connect store or indicated when you request a telecommunication service in the Porsche Connect portal or Porsche Connect store to establish, amend, or terminate a contractual relationship regarding telecommunication services or to design the content thereof. The aforementioned data are stored for these purposes until the end of the calendar year following termination of the contractual relationship at the latest.

Traffic data generated within the scope of the activity of the wireless network connections (such as the start and end of the respective connection), location data on the mobile connection, the end points of the connection and dynamic IP addresses, are not collected, processed, or used within the Porsche Connect infrastructure, with the exception of SIM card and device numbers and the volume of data used. Please contact the respective network operator for information on the nature, extent, and purpose of its collection, processing, and use of data.

9.5. Data processing within the scope of further connectivity services

If you request or have requested expanded connectivity services, such as Wi-Fi packages, activation and deactivation information is exchanged between our system, your vehicle’s wireless network interface, and the virtual network operator for the purpose of activating and deactivating the data packages of the permanently installed SIM card in Porsche vehicles.

To manage the permanently installed SIM cards in Porsche vehicles and to calculate the volume of data available to you and the volume of data used within the scope of any data package you may have requested, the vehicle identification number, your SIM card numbers, the associated SIM card status and, where applicable, the volume of data used and remaining in the respective period are additionally exchanged between our system, your vehicle’s wireless network interface, and the virtual network operator and stored by us for the duration of the respective contractual relationship. We also store the aforementioned data for a period of 30 days as a basis for generating anonymized use reports.

9.6. Further data processing due to legal obligations

Beyond the data processing described in Sec. 3 through 5 above, we collect, process, and use telecommunication data (data that are collected, processed, and used based on the provision of the telecommunication service and/or to establish connectivity) only based on and in compliance with applicable legal obligations that apply to us – for example, to fulfill our statutory obligations to store personal data for, and release personal data to, security and law enforcement agencies.

9.7. Identity checks

In some countries, it may be necessary to perform an identity check based on an identification document for legal reasons in order to request certain telecommunication services. We use the external service provider IDnow GmbH, Auenstr. 100, 80469 Munich, Germany, to perform these identity checks. The collection, processing, and use of data in connection with the identity check are performed exclusively by and on the responsibility of the external service provider. Please contact the external service provider for information on the nature, extent, and purpose of the collection, processing, and use of data. You can find this information here.

To perform the identity check, you will be redirected to the service provider’s external site as part of the service request process. At your prompting, we will transmit the information that is to be verified (your name, address, and date of birth) to the service provider, along with a procedure number in order to be able to match up the result of the identity check later on. Following the identity check, the service provider will let us know the result of the identity check under the procedure number. We do not transmit personal data from this identity check to third parties except where we are legally obligated to do so. We also receive access to a copy of your identification document stored by the service provider in these cases only, in order to fulfill our statutory obligations.

 

10. Modifications to this Data Protection Statement

We reserve the right to modify this Data Protection Statement. The current version of the Data Protection Statement is always available.

Porsche Connect Cookie Policy

What are cookies?

In order to provide you with a comprehensive range of functions when you visit our website, to recognize your preferences and make use of our web pages more convenient, we use "cookies". Cookies are small files stored using your Internet browser on your device.

Your set-ups

By using our website, you agree to the use of cookies and storing them on your computer. You can, of course, also view our website without cookies. If you would prefer not to have cookies saved on your computer, you can disable the relevant setting in the Internet options of your browser. Saved cookies can be deleted at any time in the Internet options of your browser. If you choose not to accept any cookies, this can, however, lead to restrictions in the functions offered on our website.

Categories of cookies

We use cookies for different purposes and with different functions. We distinguish whether a cookie is strictly required (technical necessity), how long it is stored and used (storage time), and whether it was set by our website itself, or by a third party, as well as which provider (cookie provider) set it.

Technical necessity

Strictly necessary cookies: We use certain cookies because they are necessary for the website and its functions can work properly. These cookies are used automatically when calling a web page or a specific function, unless you have prevented the use of cookies in the settings on your browser.

Performance cookies: In contrast, performance cookies are used to improve, for example, convenience and performance of our website or to save certain settings you make. We also use performance cookies to identify information use frequency of certain areas of our website, so we can target your needs in future. We do not store any performance cookies until you have consented by clicking the corresponding field that you have read our cookie notice and continue to use our website.

Storage period

Session cookies: Most cookies are only required for the duration of your current website and portal visit, or your session, and are either deleted or expire as soon as you leave our website, or your current session expires (so-called "session cookies"). Session cookies are used, for example, to retain certain information during your session about your authentication or your shopping basket on the portal.

Permanent cookies: Only a few cookies are stored over a long period to recognize you again when making another call on our page at a later date and to recall stored settings. This enables you to access our pages faster or more conveniently for example, or to not select certain settings such as language again. Permanent cookies are automatically deleted after a predefined time period if you visit the site or domain from which the cookie was set.

Flow Cookies: These cookies are used for communication of various internal Porsche servers with each other. They are set at the beginning of user interaction and deleted again after ending. Flow cookies receive a unique identification number during interaction that do not gather any information about the actual customer or user.

Cookie providers

Cookie providers: Generally, cookies are set by the operator assigned by us when visiting our website.

Third party cookies: So-called "third party cookies" are in contrast stored and used by other sites or web pages, for example, by providers of web analytics tools. More information about web analytics tools and audience measurement can be found further in this cookie policy. Third party providers may also use cookies to display advertising or to integrate content from social networks, such as social plug-ins.

Use of cookies for web analytics and audience measurement

We use Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our website and preferences. The information on your use of this website (including your shortened IP address) generated by the cookie is usually transferred to a server operated by Google in the USA and stored there. Google uses this information to analyse your use of the website, to compile reports on the website activities for us and to provide other services relating to the use of the website and Internet usage. Google may also pass this information on to third parties in so far as this is required by law or if third parties process the data on Google's behalf.

You can disable Google Analytics with a browser add-on if you do not want website analysis. Download this here: https://tools.google.com/dlpage/gaoptout?hl=en-GB. This stores so-called "opt-out" information on your end device, which allocates your deactivation of Google Analytics. Please note that such "opt-out" information only disables Google Analytics for the end device and the relevant browser from which it was used. In addition, you must set this again if you delete cookies from your end device.