Privacy Notice

Data Privacy policy

Thank you for visiting our website. Privacy is an important topic for Volkswagen Digital Solutions (“VWDS”). Please find out information about who we are, for what purposes we use your personal data, how we process and store it, with whom we share it, how long we retain it, as well as how you can contact us and exercise your rights – in the context of visiting the company’s website. Providing your personal data entails your knowledge and acceptance of the terms and conditions of this Privacy Policy, which must be read together with the Terms of Use and the Cookie Policy.

Data Controller

The entity responsible for processing your data is Volkswagen Digital Solutions, Unipessoal Lda., with its registered offices at Rua do Sol ao Rato, 11, 1250 – 261 Lisboa, Portugal, registered in the Commercial Registry of Lisbon, under the single registration and taxpayer number 515128171, with a share capital of 200.000,00 euros.

Collection of data

We can collect your data while you navigate through and interact with our website such as your IP address.

We can also collect your name and e-mail should you decide to contact us via our online contact form.

Legal basis and purpose for data processing

Your personal data is collected, processed and transferred only for the intended purpose and only if there is a pertinent legal basis for doing so. Specifically, we use personal data for the following purposes:

  • Providing information and/or replying to a contact request, based on our legitimate interest in ensuring an answer to any request for information from visitors of our website. For this purpose, we shall process your identification and contact data. The processing of this data is essential for us to reply to your contact request and failure to provide it will prevent us from registering your request.
  • Improving and personalizing your experience on our website, to ensure that content from our website is optimized for you and for your computer or electronic device, based on our legitimate interest or, when applicable, on the data subject’s consent to the use of cookies. For more information, please see our Cookie Policy.
  • Recruiting and selection of employees, entering into and executing contracts or related precontractual processes, based on (i) your consent for spontaneous applications or (ii) pre-contractual procedures at the data subject’s request or in order to comply with legal and/or contractual obligations, to the extent that is necessary, as established in the applicable Portuguese law, for publicly open positions available in our website.

Should you apply for a recruitment process, the following personal data will be processed:

  • First Name;
  • Middle Name;
  • Last Name;
  • Email Address;
  • Mobile Phone Number;
  • Address;
  • Curriculum Vitae.

Subsequently, if you accepted a job offer, we will process the following personal data from you:

  •  First Name;
  • Middle Name
  • Last Name;
  • Email Address;
  • Mobile Phone Number; 
  • Address;
  • Curriculum Vitae;
  • Photo;
  • Nº of Citizen Card or Passport;
  • Tax Number;
  • Social Security Number;
  • Degree Certificate.

The processing of this data is essential for us to consider your application and failure to provide it will prevent us from registering your request.

  • Sending of relevant communications related to recruitment process, based on your consent. For this purpose, we shall process your identification and contact data, as well as any professional data you decide to provide us, so we may adapt the relevant vacancies to your professional background.
  • In case you visit our offices, we may collect your image data, as we have surveillance systems installed for the purposes of our legitimate interests of protecting people and property. Without prejudice to the possibility to exercise your rights, the processing of this data is inevitable in case you walk by the surveilled areas.

Disclosure of data

Volkswagen Digital Solutions will disclose your data in the following situations:

  • Service providers: these are external companies used to help us to in the daily activities (e.g. website operation, market research companies, support services, website development, data analysis, recruitment, etc.). Service providers can only access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.
  • Other companies of the Volkswagen Group: we may disclose your data to other Volkswagen companies based on data processing agreements and intragroup services.
  • Authorities and official entities: we may disclose your information under the applicable law, to ensure compliance with legal obligations/judicial orders, in line with decisions of the relevant supervisory authorities, or to respond to requests issued by public or governmental authorities.

In any of these situations, VWDS will take all appropriate measures to ensure the effective protection of your personal data.

If VWDS transfers personal data to third countries (countries that are neither a member of the European Union nor the European Economic Area), we ensure strict compliance with the relevant data protection regulations. For example, VWDS only transmits personal data to processors (e.g., IT service providers) in third countries if the EU Commission has passed a resolution that this is appropriate for the respective third country or if the data transfer is adequately protected by EU standard contract clauses (and, if needed, supplemental security measures) as created by the EU Commission that have been concluded with the processor.

To obtain a copy of these appropriate safeguards (where applicable), you should send your request to the following email address: data.protection@vwds.pt.

Retention of personal data

We will only keep your data for as long as necessary for the purposes set out in this Policy and legally permissible.

As per any information requests you may issue, we will delete any personal data you may have provided us, as soon as we are able to answer and close your request.

As per the retention periods of the website’s cookies, please consult our Cookie Policy, which contains updated information for each cookie.

On what concerns the communications we may send you about interesting job offers, we will keep your data for as long as necessary and, in any case, we shall stop processing it in case you withdraw your consent.

As per recruitment procedures you apply for, even if your application is not successful, are legally obliged to store some of your personal data, for a minimum of 5 years, as per Portuguese Labor Code, article 32. As per your CV, it shall be deleted within 1 year from your initial application in case you are not selected for the job offer. If you are hired, your information shall be retained for as long as you are employed by VWDS.

With regard to the surveillance images, pursuant to the applicable laws, we shall retain them for 30 days and will necessarily delete them within the subsequent 48h.

After the period necessary for the fulfilment of the purposes of the data processing carried out by VWDS, the data will be permanently deleted or anonymized.

Your rights

At any time, you may exercise any of the following rights:

Access: You have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data.

Consent: you are also entitled to withdraw your consent for the processing of your data for the stated purposes in which it is the applicable lawful basis for data processing. This will not, however, affect the lawfulness of any processing carried out before consent was withdrawn.

Rectification of inaccurate or incomplete data: You may at any time request the rectification of any inaccurate or incomplete data concerning you.

Deletion: You may request the deletion of data without undue delay, and VWDS shall be obliged to erase personal data without undue delay whenever one of the following grounds applies, in particular:

  •  If data are no longer necessary for the purpose for which they were collected or processed;
  • You objected to the processing and there are no overriding legitimate interests justifying said processing; or
  • You have withdrawn your consent to the processing of data (where processing is based on consent) and there is no other ground for such processing.

Please note that, in certain circumstances, we may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.

Restriction of processing: You have the right to ask VWDS to limit the processing of your data if, inter alia, one of the following applies:

  • If you contest the accuracy of the personal data, for a period that allows VWDS to verify their accuracy;
  • The data processing is lawful and you object to the erasure of the personal data and request, in return, the limitation of its use;
  • If VWDS no longer needs the personal data for processing purposes, but such data is required by you for the purposes of asserting, exercising or defending a right in legal proceedings;
  • If you have objected to the processing, until it is established that the legitimate reasons of the controller override those of the data subject.

Objection to the processing of personal data: You may object to the processing of your personal data whenever the data processing is carried out on the basis of legitimate interests pursued by VWDS. In this situation, we may be able to demonstrate the existence of legitimate grounds which outweigh your legitimate interests.

The rights listed above can be exercised at any time by contacting data.protection@vwds.pt.

We hope that we can satisfy any queries you may have about your Personal Data. However, and without prejudice to any other form of administrative or judicial appeal, you are entitled to file a complaint with the relevant supervisory authority. More information on the various European national data protections authorities is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

Information Security

VWDS implements and assures the maintenance of adequate protection means, so that its internal procedures for personal data security are in accordance with the regulations in force. VWDS also develops all the necessary efforts to ensure that contractually, the third parties with whom it collaborates, as partners or service providers, guarantee an adequate protection of the personal data they have access to. VWDS limits the access to personal data to specific employees, and only when their contact with such personal data is justified within the scope of their functions.

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

Visitors are, however, responsible for ensuring that their devices and equipment used to access our site are appropriately protected against any damaging software, viruses and worms. Visitors should further be aware that failure to adopt adequate security measures (for example, the secure configuration of the browser, updated antivirus software, the use of a firewall and the non-use of questionable software) will increase the risk of personal data being accessed by unauthorized third parties.

If any defect, bug or anomaly is detected in our site, you must immediately communicate this to VWDS and not seek to exploit such defect, bug or anomaly to access commercial information or the personal data of other data subjects, change the features of our site or use it in an irregular or unlawful manner or contrary to VWDS’ design.

Changes

VWDS reserves the right to, at any time, change and update this Privacy Policy. Any changes will be published on our website. Please check it back frequently.

Created: Lisbon, 24.07.2019

Updated: 12/09/2024