VW privacy policy
At Volkswagen Group Canada Inc. ("VW Canada", “we”, “us” or “our”), your privacy is important to us. This privacy policy (the “Policy”) explains VW Canada’s privacy practices as well as the choices you can make about the way we collect, use and disclose your personal information.
Definitions of “personal information” may vary from one jurisdiction to another but generally, “personal information” means any information about an identifiable individual. Personal information may, for example, include direct or indirect identifiers such as a person’s name or driver’s license number, as well as information that, when used in combination with other available information, allows a person to be identified. Your rights in relation to your personal information may also vary depending on where you live.
To make this Policy easy to find, we make it available on our website at www.vw.ca.
If you are unsure if or how this Policy applies to you or have questions about this Policy, or our personal information handling practices, please contact our Privacy Officer at: privacy@vw.ca.
Click on the links below to find the information you are looking for more quickly.
PERSONAL INFORMATION WE COLLECT
HOW WE COLLECT YOUR PERSONAL INFORMATION
WHY WE COLLECT YOUR PERSONAL INFORMATION AND HOW WE USE IT
HOW WE SHARE PERSONAL INFORMATION
INTERNATIONAL OF INTERPROVINCIAL TRANSFERS OF PERSONAL INFORMATION
COLLECTION OF PERSONAL INFORMATION FROM MINORS
DE-IDENTIFIED AND ANONYMIZED INFORMATION
OUR USE OF COMMERCIAL ELECTRONIC MESSAGES
OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES
HOW TO CONTROL YOUR COOKIE PREFERENCES
OUR USE OF THIRD PARTY ADVERTISING SERVICES AND THEIR USE OF BEHAVIORAL TRACKING
OUR COMMITMENT TO THE SECURITY OF PERSONAL INFORMATION
IF YOU CHOOSE TO USE CAR-NET® SERVICES
WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION IN CONNECTION WITH THE CAR-NET® SERVICES?
Your Personal Information
In Summary
What personal information we collect and how. The personal information we may collect about you and how we obtain it varies depending on the nature of our relationship with you and how you interact with us. For example, we may collect information when you visit our website, attend special events, complete our customer surveys, when you request and/or receive any products or services from us or if you communicate with us through one of our customer care representatives (or any AI chatbot tool) or contact us by email, telephone or through social media. We may also obtain personal information about you indirectly through our dealers, our affiliates (e.g., Volkswagen Financial Services) and others who provide information to us.
Generally, the personal information we may collect falls into the following categories, not all of which may apply to you: (i) contact information such as your name, address, telephone number, and e-mail address; (ii) financing and payment information (including billing and authorization information); (iii) information concerning vehicle use; (iv) information relating to your use of the Car-Net® Services (as defined below) ; and (v) information relating to individual preferences of our products and services.
Why we collect personal information and how we use it. Our reasons for collecting your personal information and how we use it will vary depending on the nature of our relationship with you but generally, we only use and share personal information for the purposes for which it was collected, unless we are legally allowed to use it for another purpose. For example, we may collect and use your personal information to manage our relationship with you, to communicate with you, to obtain your feedback, to improve our products and their safety features on an ongoing basis, to conduct research and marketing activities, and to defend our legal rights and comply with the law.
How we share personal information. We may share your personal information with our dealers, our affiliates, and our other service providers (e.g. satellite radio providers) for the purposes described in this Policy. We may also share personal information to technical support service providers, customer relationship management (CRM) software service providers, and data storage and processing service providers that are assisting us in fulfilling the purposes for which we collected the personal information. We may also disclose your personal information to a third party in the event of a significant business transaction involving VW Canada, such as a merger or reorganization of our business.
For more details about the personal information we collect, how we collect it, and how we use and share it, please read the sections below.
Personal Information We Collect
General Information We Collect
We collect and maintain different types of personal information concerning the individuals with whom we interact. For example, we may collect:
- your contact information, such as your name, mailing address, telephone number, e-mail address, driver’s license, and insurance information;
- information used to verify your identity;
- your payment information, including your credit card number, CVV code and expiry date;
- your financial and credit information as disclosed to us by VW Credit Canada, Inc. ("Volkswagen Financial Services"), when you have provided your consent;
- information which enables us to provide you with the products or services that you seek, including any information you provide to us when you create or maintain an account with us (e.g., a “Volkswagen ID” account);
- information which enables us to offer you products and services which we believe may be of interest to you, including information about your interests, purchase patterns, incentive eligibility, vehicle purchase intentions, and demographic information (e.g. age, gender, education level, occupation, and marital status);
- information about your use of certain services that we may provide to you, or that may be provided through your vehicle;
- information about your vehicle, including: (i) your vehicle's make, model, and model year; (ii) vehicle identification number (VIN); (iii) license plate number; (iv) whether it was a new or used, lease or purchase, and/or a trade-in; (v) date of purchase or lease; (vi) the term of your lease or financing and other loan-related information; (vii) service information (e.g. service history, recalls, warranty and repair data, mileage, diagnostic data about the performance or status of vehicle modules and systems); and (viii) applicable third party service providers (e.g. cellular provider, satellite radio provider, etc.);
- information gathered by your vehicle and how you interact with it. For example, your vehicle may contain an event data recorder ("EDR"), which can collect and store information about your vehicle and its occupants immediately before and during a collision or near collision event (including how various systems in your vehicle were operating (such as your accelerator and brakes), as well as the speed of your vehicle), diagnostic information, and information about the deployment of the airbags. For additional information about your EDR, please see your owner's manual;
- information about your connected devices (including laptop, cell phone and tablet), including type/model of the connected device, browser types and settings, IP address, network information;
- information that you submit to us or any of our service providers (including photographs, videos, questions or prompts) through or in connection with contests, sweepstakes, social media, contact forms, or your use of human or AI-enabled chat features on our website or app, through written or verbal communications with any of our representatives or AI chatbot tools, or through any other means; and
- spoken data (and any personal information included therein) when using voice command features or when you speak to a customer care representative or use an AI chatbot tool.
Information We Collect Through Connected Car Services (e.g., Car-Net®) and Mobile Applications
Car-Net® Services. In addition to the foregoing, if you choose to activate our connected-car services, including but not limited to Car-Net®, the Car-Net® mobile application and/or account on the Car-Net® website, DriveViewTM, or any similar or related services such as a Volkswagen ID account (the "Car-Net® Services") (whether through a plan offered at no additional cost or a paid subscription), we may collect additional personal information in connection with this service, including:
- account information, such as billing, settings, personalized services and authentication information;
- information that you provide when using the Car-Net® Services, including information you send and information you request;
- vehicle data transmitted from your vehicle or inferred from your use of the vehicle or our services, such as general status data (e.g. warning lights, upcoming service schedule, fuel level, battery level, tire pressure); service history and fault or trouble codes; ambient data (e.g. outside temperature and brightness); vehicle performance data; other data about your vehicle including its identification, condition, equipment status, or collision information; vehicle/technology usage data (e.g. usage of start/stop and remote start technology);
- driver behavior data (e.g. vehicle speed, seat belt use, and information about braking habits), time at which the vehicle is in use, GPS location data, and inferences, such as postal code of residence, that the primary driver is a routine long commuter, or frequency of individual versus multi-person use;
- information about your use of (i) the Car-Net® Services; and (ii) any applicable mobile application and/or website; and
- information about your interactions with us, our affiliates, or our third party service providers, Integrated Content Providers and Optional Third Parties (each as defined below).
Over-The-Air Updates. If your vehicle is equipped with online “over the air” system update capability, we will also collect software and hardware version and serial numbers of vehicle hardware and use this information to provide online system updates.
Other VW Applications. VW Canada may also have other mobile applications that you can download to your mobile device or vehicle (“VW Applications”). When you download a VW Application, there may be an opportunity for you to provide us with or for us to obtain information about you or your vehicle. Each VW Application will display a privacy policy that will inform you about how any new or different information shared via the application will be handled. Otherwise, information collected via VW Applications will be the information identified above and will be used and shared as stated in this Privacy Policy.
Third-Party Applications. Through the Infotainment system, VW may also offer applications developed by third parties, for example Apple CarPlay or Android Auto (“3rd Party Application”). When you download a 3rd Party Application to your mobile device or vehicle, the 3rd Party Application may collect information about you or your vehicle in connection with your download or use of that application. VW Canada is not responsible for the collection or use of information by 3rd Party Applications. We recommend that you carefully review the privacy statement and terms of use of each 3rd Party Application prior to downloading or using them.
How We Collect Personal Information
We may collect your personal information from you when, for example:
- you visit our website;
- you use our products and services (e.g. warranties, extended service plans, or roadside assistance);
- you interact with our customer relations representatives or an AI chatbot tool;
- you attend special events organized by us;
- you complete customer surveys;
- you participate in a contests, sweepstakes or social media;
- you use your vehicle and when your personal information is captured by it (“Vehicle Data”);
- through the Car-Net® Services or VW Applications as described in the “Information We Collect Through Connected Car Services (e.g., Car-Net®) and Mobile Applications” section in this Policy.
From our Dealers. We may also obtain your personal information from our dealers (each a "VW Dealer") when you buy or lease a vehicle, or obtain any services from them. Please note that VW Canada and each VW Dealer are separate legal entities. We each have our own privacy policies. When you visit or interact with a dealer, please be sure to read their privacy policy in addition to this VW Canada Privacy Policy to fully understand how each entity collects, uses and shares personal information. Because your VW Dealer is often your first point of contact, your VW Dealer should be able to answer any questions you may have about its privacy practices. Any questions concerning your VW Dealer’s privacy policies and procedures (including opting out of marketing communications) should be addressed directly to your VW Dealer.
From Volkswagen Financial Services. We may also collect your personal information from Volkswagen Financial Services so that we may: (i) process your information on their behalf; and (ii) send you marketing information about our vehicles, products or services, events and promotional or loyalty offers (including finance or lease offers).
From other Third Parties. We may also obtain your personal information from third parties who help us operate our business. For example, we may conduct joint marketing activities (such as contests, sweepstakes or social media) through which we may obtain your name and address and other information about you. We may also use third parties to help us conduct surveys or fulfill our customer service operations (including to facilitate AI chatbot tools you may interact with) and thus obtain information about you from them. Lastly, we may use third parties to help us manage, process, store and/or understand the information we have about you and others (e.g., Customer Relationship Management solutions such as Salesforce). When we engage such other third parties to provide services for us, we contractually bind them to certain terms to ensure that they only collect, use and disclose your personal information per our instructions and for purposes disclosed to you either in this Policy or at the time your information is collected. In some cases, those other third parties will collect information from you on our behalf and may wish to use your personal information for their own purposes, in which case they are responsible for telling you about those other purposes before they collect your personal information. You should therefore make sure to read their privacy policies so that you understand how both we and they may use and disclose your personal information. Any questions concerning their privacy policies and procedures (including opting out of marketing communications) should be addressed directly to such third parties.
Why We Collect Your Personal Information and How We Use It
VW Canada collects personal information (as well as Vehicle Data) to enable us to develop, manage and maintain our operations and business, including for example:
- to establish, maintain and manage our relationship with you so that we may provide you with the products, information or services that have been requested (including, for example, to respond to your questions or requests for products, information or services, to enable you to create an account with Volkswagen (e.g., a Volkswagen ID account), and to enable you to register, subscribe and/or use various services provided by Volkswagen or third parties);
- to be able to review the products and services that we provide to you so that we may:
- understand your requirements for our products and services;
- understand your preferences and needs; and
- work to improve our products and services;
- to administer or assist our dealers or Audi Finance with the administration of your vehicle warranty, purchase, lease or financing;
- to provide you with information about your vehicle (including product campaigns and recalls);
- to send you marketing materials about our vehicles, products or services, events and promotional or loyalty offers;
- to conduct market research;
- to build and maintain a customer profile of you to be used for any of the above purposes;
- to protect us against error, fraud, theft, and damage to our goods and property;
- to enable us to comply with applicable laws or regulatory process;
- to respond to questions, requests, or prompts you share with us as part of your use of an AI chatbot tool;
- to enable us or our service providers to operate, develop, monitor, improve, or train AI models that you use (e.g., where you use an AI chatbot tool) or for another business purpose related to the offering of a chatbot tool, such as to reproduce, modify, create derivative works, publicly perform, or publicly display personal information in the chatbot tool, as necessary to enable the chatbot service, including after de-identifying and aggregating your personal information for these purposes;
- for any other purposes described in this Policy; and
- any other reasonable purpose to which you consent at or before the time we collect your applicable personal information.
If you choose to use the Car-Net® Services, we will also use your personal information for purposes in line with those services. For detailed information about the Car-Net® Services, see the “If You Choose to Use Car-Net® Services” section in this Policy.
How We Share Personal Information
For the purposes outlined in this Policy, we may share your personal information with:
- Volkswagen Financial Services;
- VW Dealers;
- our affiliates, including Audi Canada Inc., Volkswagen Group of America, Inc. ("Volkswagen America") and Volkswagen Aktiengesellschaft ("Volkswagen AG");
- third party service providers, including our suppliers, contractors, professional advisors, and affiliates that perform services for us (e.g. (i) data hosting, network and other information technology services, including AI chatbot services (ii) customer service, (iii) marketing services, (iv) payment processing, and (v) legal, accounting and other professional services); and
- appropriate authorities to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a law enforcement request.
We may also share your personal information as required or permitted by law (for example, in connection with an investigation or subpoena).
Our Partnership With SiriusXM
When you purchase or lease a Volkswagen vehicle from a Volkswagen dealer (or otherwise) that is equipped with a trial subscription to SiriusXM satellite radio, we and/or our Volkswagen dealers may share your personal information with Sirius XM Canada Inc. and/or its affiliates (collectively, the "Sirius XM Entities"), including for example: (i) your name, address, phone number, and email address; and (ii) the model, model year, and VIN of your vehicle, the "electronic serial number" or "RadioID" of your vehicle's SiriusXM receiver, and the date when the vehicle was leased/sold to you. This information is shared in order to: (x) complete the activation of your free SiriusXM trial subscription; (y) allow the Sirius XM Entities to contact you regarding the free SiriusXM trial subscription and to provide you with any additional products, services, or offers that you may be interested in (to the extent applicable); and (z) enable any of the Sirius XM Entities to send you marketing materials (e.g. offers for additional subscriptions to SiriusXM satellite radio) by email or otherwise. For further details about Sirius XM Canada Inc.'s privacy practices, please review its privacy policy. To allow the SiriusXM Entities to better understand your needs and to improve their respective products and services, they may collect, use and share data relating to the performance and/or usage of SiriusXM in your vehicle. VW Canada does not control SiriusXM’s practices with respect to that data as it relates to your use of their services. Please review their privacy policy for more information. Where applicable, you can withdraw your consent from receiving marketing communications from SiriusXM at any time by contacting SiriusXM directly in the manner indicated in their privacy policy. If you have any questions about the foregoing, please contact VW Canada at privacy@vw.ca and we will try to assist you.
Other Third Parties
When you request or purchase certain products and services from a third party service provider through us (e.g. Wi-Fi hotspot services), we may share your personal information with that service provider in order for that service provider to: (i) create and manage its relationship with you; and (ii) provide you with the products and/or services that you seek or as otherwise described in this Policy.
We may also share your personal information with Electrify Canada and our other affiliates, partnerships and joint ventures for the purposes of administering our respective businesses, including for example, confirming the purchase or lease of any products or services that you may have made from us or one of our authorized VW Dealers.
Finally, your personal information may be disclosed or transferred to another party during the course of (i) the grant of a security interest in VW Canada's assets, or (ii) completion of the sale of all or a part of VW Canada through (for example, an asset or share sale, or some other form of business combination, merger or joint venture); provided, however, that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in accordance with this Privacy Policy.
International or Interprovincial Transfers of Personal Information
We may transfer your personal information to a jurisdiction other than the one in which it was collected in order to fulfil the purpose outlined in this Privacy Policy or for other processing and storage purposes permitted by law. When your personal information is outside of its jurisdiction of origin, it is subject to the laws of the country or province in which it is located, which may have different data protection laws than those in force in its originating jurisdiction. Those laws may make it possible for your information to be accessed by law enforcement and national security authorities in that other jurisdiction. For example, we could be obliged to respond to a subpoena or other mechanism that would give law enforcement officials in that other jurisdiction access to your personal information.
Collection of Personal Information from Minors
We do not seek to obtain, nor do we wish to receive, personal information directly from minors; however, we cannot always determine the age of individuals with whom we interact (e.g. individuals who access and use our websites). If a minor (as defined by applicable law) provides us with his or her personal information without parental or guardian consent, we encourage the parent or guardian to contact us.
De-Identified and Anonymized Information
To the extent allowed under applicable laws, us and our service providers may de-identify or anonymize your personal information, and use and disclose such de-identified or anonymized information for any purpose (including to develop, manage, and maintain our business) without further notice to you.
Our Use of Commercial Electronic Messages
VW Canada will only send you commercial electronic messages if we have your implied consent or express consent to do so. For example, we may send email, text or other electronic messages to you: (i) if you have an existing vehicle warranty, purchase a service directly from us, or have some other form of existing business relationship with us; or (ii) if you have asked for or otherwise expressly agreed to receive such electronic messages from us, such as by signing up for our newsletter or by agreeing to receive marketing communications from VW Canada in the context of one of your interactions with a dealer. You can withdraw your consent or request to stop receiving such messages at any time either by using the unsubscribe mechanism within the body of any such message or by contacting our Privacy Officer at privacy@vw.ca.
Our Use of Cookies and Similar Technologies
For details on how we and our partners use cookies, please see our Cookie Policy , which forms part of this Policy.
How To Control Your Cookie Preferences
There are a variety of ways in which you can control the information collected by cookies and similar technologies when you use our websites or apps. For example, you can control the cookies used by modifying the settings in your browser or on your device that allow you to change the setting of all or some cookies. Through those settings, you should also be able to delete cookies that have already been placed on your devices. For information and instructions on how to change your cookie settings on different browsers and mobile devices, see here.
Please note that if you use your browser or device settings to block all cookies, you may not be able to access all or parts of our websites, apps, or services.
Our Use of Third Party Advertising Services and Their Use of Behavioral Tracking
We may use technology to serve advertisements on our own websites and within its content as that content is served across the Internet. In addition, we may use third party ad networks, publishers and other entities to serve advertisements (including via Facebook) and third party analytics vendors to evaluate and provide us with information about the use of our websites and the viewing of our content on our and other platforms.
Ad network providers, data providers, publishers and other media-related companies, and/or analytics service providers may set and access their own cookies, pixel tags and similar technologies on your device's web browser and they may otherwise collect or have access to information about you. We and they may target advertisements for products and services in which you might be interested based on your visits to both the VW Canada websites and other websites. We and they may use a variety of companies to serve advertisements.
You can control the information we collect about you for these purposes through cookies and similar technologies. Please see the “How To Control Your Cookie Preferences” section above for more information on how to change your cookie settings.
Our Commitment to the Security of Personal Information
We maintain appropriate physical, organizational, contractual and technological measures and follow generally accepted industry standards to preserve and safeguard the confidentiality and integrity of your personal information against accidental or unauthorized access, use, disclosure, alteration, destruction or accidental loss.
Despite these measures, we can’t guarantee that our safeguards will always be effective. For example, hardware or software failure, and other events such as a ransomware attack may compromise the security of your personal information. In such cases, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.
If you have reason to believe that your interaction with us is no longer secure or if you feel that the security of any information that you provided to us or that is under our control has been compromised, please advise our Privacy Officer using the contact information set out below.
Your Consent Is Important
When it is required, it is important to us that we have your consent to collect, use or disclose your personal information. Depending on the sensitivity of the personal information and on the applicable legal requirements, your consent may be implied or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time, unless express consent is required.
If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or disclosure, unless we are permitted by law to proceed without obtaining your consent. Privacy laws in Canada provide for certain exceptions where personal information can be used or shared without consent.
Please be advised that we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. These circumstances include, for example, personal information which is subject to solicitor-client privilege, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, to investigate a breach of an agreement or a contravention of a law, to act in response to an emergency that threatens the life, health or security of an individual, for debt collection, or to comply with a subpoena, warrant or court order.
Retention
We will retain your personal information for as long as necessary to fulfil each of the purposes for which it was collected, or as otherwise permitted or required by law. When this retention period expires, your personal information will either be anonymized or destroyed. If you would like more information on how long we retain your personal information, please contact our Privacy Officer using the contact information set out below.
Your Rights
Your rights relative to your personal information may vary depending on where you live. When contacting us to change or withdraw your consent or when requesting access to or correction of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a reasonable fee to provide you with a copy of your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
You can exercise all of the rights listed below by submitting a request in writing to our Privacy Officer using the contact information set out below.
Withdrawing Your Consent. You have the right to change or withdraw your consent to the further communication or use of your personal information at any time, subject to reasonable notice and to certain limitations such as legal or contractual obligations. Please note that in some cases, the withdrawal of consent may render us unable to continue to provide you with products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.
Accessing Your Personal Information. You have the right to request to view and/or obtain a copy of your personal information. Please note that your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, your personal information may have been destroyed, erased or made anonymous.
Correcting Your Personal Information. You have the right to request that any incomplete or inaccurate personal information we hold about you be corrected, subject to certain limitations. That said, it is important that the information contained in our records is both accurate and current so if your personal information happens to change during the course of our relationship, please keep us informed of such changes.
How to Contact Us
All complaints or requests for information should be made to our Privacy Officer at:
Volkswagen Group Canada Inc.
777 Bayly Street West Ajax, ON, L1S 7G7
Attention: Privacy Officer
E-mail: privacy@vw.ca.
If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer using the contact information set out above. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may also contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner. For more information, please go to https://www.priv.gc.ca/en/.
Interpretation of This Policy
Any interpretation associated with this Policy will be made by our Privacy Officer. This Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word "including" is used, it shall mean "including without limitation".
This Policy does not create or confer upon any individual any rights, or impose upon VW Canada any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Policy and Canada's federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
Changes to this Policy
We may make changes to this Policy from time to time. Accordingly, we encourage you to refer back to it on a regular basis. The most current version of the Policy will always be posted on www.vw.ca.
This Privacy Policy is effective as of August 2023.
If You Choose to Use Car-Net® Services
The Car-Net® Services are provided by or on behalf of VW Canada. The following applies to information we obtain from and about individuals interacting with the Car-Net® Services for VW Canada Model Year 2022 vehicles and newer, and the VW Canada Car-Net®-related websites, mobile applications, and services, as well as older models if the owner or registered user upgrades to the latest version of Car-Net® Services and accepts the applicable Terms of Service.
You can discontinue the Car-Net® Services data collection described below at any time by un-enrolling your vehicle from Car-Net® Services via the Car-Net® website, Car-Net® mobile app or by calling Car-Net® Response Center at 1-833-435-1011. However, this will result in loss of Car-Net® Services.
This Privacy Policy also applies to drivers and users of rental cars and other company fleet vehicles that have Car-Net® Services activated by the owner or fleet manager. When you use the Services or drive a vehicle from such fleet with active Services, this Privacy Statement shall apply to your use. Additional data use and sharing and terms and conditions may apply to Services provided to fleet vehicles, which will govern if they conflict with this Privacy Policy. The owners or managers of the fleet may use the data collected through the Car-Net® Services in additional ways that are not covered in this Privacy Policy. Therefore, you should check with the owners or managers of the fleet or rental cars if you have questions about any requirements, limitations, or data practices that may apply to your use of the Car-Net® -equipped vehicle or Services. Rental car companies and fleet owners are responsible for ensuring that drivers and users are made aware of this Privacy Policy and the VW Car-Net® Terms of Service.
What Information Do We Collect in connection with the Car-Net® Services?
The information that we may collect about you in connection with the Car-Net® Services is described in section above called " Information We Collect Through Connected Car Services (e.g., Car-Net®) and Mobile Applications".
Please note that the information stored in your vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your vehicle or mobile device, and thus may be deleted, altered, or transferred. You should especially take care to delete any stored data before you sell, return (in the case of a lease) or otherwise transfer your vehicle to someone else and information stored in your vehicle may also be accessible to a new owner of your vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.
We do not store the content of any messages (such as social media messages) that you transmit or access through the Car-Net® Services.
How Do We Use Your Personal Information in connection with the Car-Net® Services?
In addition to the general purposes described in this Privacy Policy, we may use the information generated in association with your use of Car-Net® Services to provide you with such services.
If you opt-in to DriveView™, we will use information collected through Car-Net® Services about your driving behavior, such as speed, braking and seat belt usage, and GPS location in order to assess your driving and routinely provide you a DriveView™ score (i.e. a score based on certain factors that are considered higher indicators of risk of collision, such as hard braking, nighttime driving, idle time and excessive speed). We also will use anonymized, aggregated data to conduct driver behavior modeling (for example, comparing drivers across different provinces).
How Do We Use Your Personal Information in connection with the Car-Net® Services?
In addition to the general purposes described in this Privacy Policy, we may use the information generated in association with your use of Car-Net® Services to provide you with such services.
If you opt-in to DriveView™, we will use information collected through Car-Net® Services about your driving behavior, such as speed, braking and seat belt usage, and GPS location in order to assess your driving and routinely provide you a DriveView™ score (i.e. a score based on certain factors that are considered higher indicators of risk of collision, such as hard braking, nighttime driving, idle time and excessive speed). We also will use anonymized, aggregated data to conduct driver behavior modeling (for example, comparing drivers across different provinces).
With Whom Do We Share Your Personal Information in connection with the Car-Net® Services?
In addition to the sharing identified above, if you subscribe to the Car-Net® Services, we may share your information with:
- Integrated Content Providers;
- Optional Third Parties;
- Wi-Fi Providers;
- First responders; and
- VW Dealers.
Integrated Content Providers
The Car-Net® Services may include offerings from various third parties with whom we contract to provide their products and services through our vehicles (“Integrated Content Providers”) whose services are integral to the Car-Net® Services, and without which many of the Car-Net® Services may not work. VW Canada collects and shares information (including your personal information) with these Integrated Content Providers and receives information from these Integrated Content Providers for the purposes of enabling you to receive certain Car-Net® Services.
Optional Third Parties
In addition to the Integrated Content Providers’ services available as part of the Car-Net® Services, you may be able to obtain or purchase additional products or services from other third parties that we introduce or with whom you independently engage through the Car-Net® platform (“Optional Third Parties”). Such products and services are not integral to the basic operation of the Car-Net® Services, but may be added by you in order to receive additional services and/or content from the Car-Net® platform. Products or services from such Optional Third Parties will be subject to their own terms of service and privacy policy. Examples of services provided by Optional Third Parties may potentially include: remote package; fuel or other in-vehicle delivery; car sharing; tolling pricing; usage-based insurance; or other third party services. Products or services from such Optional Third Parties will be subject to their own separate terms and conditions and privacy statements that you will need to accept in order to receive such products or services.
Wi-Fi Providers
To the extent applicable, we may share your personal information, including your name, contact information, equipment ID and financial information, with one or more third party mobile network operators (each a "Wi-Fi Provider"). The purpose for doing so is to enable a Wi-Fi Provider to: (i) provide you with the Wi-Fi services that you may request; and (ii) establish and manage its relationship with you. For details with respect to a Wi-Fi Provider's handling of your personal information, please review its privacy policy and/or terms of service.
First responders and Roadside Assistance Service Providers
We will also share your information as required with emergency services (e.g. police, ambulance) as well as roadside assistance service providers for the purposes of providing certain Car-Net® Services.
VW Dealers
We may also share your personal information with VW Dealers so that they too may provide you with certain Car-Net® Services (for example, alerting you when there is a potential service needs for your vehicle).