Data Privacy Policy

Thank you for visiting our website and for your interest in our company. The protection of your personal data is a matter of great importance to us. Below we inform you about the han-dling of your personal data when visiting our website www.sg.audiondemand.com as well as in the context of our Audi on demand services operated by Premium Automobiles (“PAL”) in co-operation with Audi Singapore Pte. Ltd.

If you access our website from within the European Union, our personal data processing ac-tivities may fall into the ambit of the European General Data Protection Regulation (“GDPR”) and hence require a legal basis in the GDPR. The respective legal bases are mentioned in this privacy policy and the information provided is in line with what is required pursuant to art. 12, 13, 14, and 21 of the GDPR. In addition to the GDPR, the Singapore Personal Data Pro-tection Act (“PDPA”) is applicable to our personal data processing activities.

Personal data means any information relating to an identified or identifiable natural person. This includes information such as the name, address, phone number and date of birth as well as the IP address.


I. Responsible Body

Data Controller according to GDPR:
Premium Automobiles Pte Ltd.
281 Alexandra Road,
Singapore, 1599938
contact@sg.audiondemand.com

Contact details of our data protection officer:
Audi Centre Singapore
281 Alexandra Road,
Singapore, 1599938
contact@sg.audiondemand.com
Tel.: (+65) 6690 0280


II. Purposes and Legal Basis of the Data Processing

1. Informational Use of the Website
You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. do not log in, register, book an Audi or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website as well as information that is transmitted to us through cookies used for statistical analysis of the use of our website.

a. Technical Provision of the Website
For the purpose of the technical provision of the website, it is necessary that we process cer-tain automatically transmitted information about you so that your browser can display our website and you can use the website. This information is automatically collected for each visit of our website and stored in our server log files. This information refers to the computer sys-tem of the requesting computer. The following information is collected thereby:
• IP-adresse
• Browser type / -version (e.g.: Firefox 59.0.2 (64 Bit));
• Browser language (e.g.: German);
• Operating system (e.g.: Windows 10);
• Name of service provider;
• Internal resolution of the browser window;
• Screen resolution;
• Javascript activation;
• Java on / off;
• Cookies on / off;
• Color depth;
• http-status code;
• Date and time of access.

Furthermore, we use cookies to make our website available to you for use. Cookies are text files that are stored in the internet browser or by the internet browser when you visit a website on your computer system. A cookie contains a characteristic string of characters that ena-bles a unique identification of the browser when the website is called up again. We use these cookies exclusively to provide you with our website and its technical functions. Some func-tions of our website may not be offered without the use of cookies. The following information is stored in the cookies and transferred to us:
• Session id
• Log-in status

Your information, collected by us through the aforementioned cookies, will not be used by us to create user profiles or to evaluate your browsing behavior.

To the extent a legal basis for our data processing activities is required under the GDPR, we process your personal data for the technical provision of our website on the following legal basis:
• for the fulfilment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 letter b GDPR, provided you visit our website to obtain infor-mation about us; and
• to protect our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR in order to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website.

b. Statistical Analysis of Website Usage and Range Increase
For the purpose of statistical analysis of the use of our website, we use Kenshoo and Dou-bleClick and thus cookies, which enable an analysis of your browsing behavior as well as the management of our marketing measures. This enables us to improve the quality of our web-site and its content. We learn how the website is used and can thus continuously optimize our offer.

The information obtained in the context of the statistical analysis of our website will not be merged with your other data collected in the context of the website.

To the extent a legal basis for our data processing activities is required under the GDPR, we process your personal data for statistical analysis of the use of our website on the following legal basis:
• Your consent pursuant to art. 6 para. 1 letter a GDPR.

DoubleClick Floodlight
We use the marketing tool DoubleClick Floodlight for conversion tracking as part of Google DoulbeClick Digital Marketing. DoubleClick Floodlight is an analysis service by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; „Google“). When you click on an ad placed by Google, a conversion tracking cookie is placed on your computer.

If you visit certain pages of our website and the cookie has not yet expired, Google and we can determine that you clicked on one of our ads and were redirected to this page. By using this method, we can measure whether users perform certain actions, like contact us or book an Audi, after coming to our website through one of various marketing channels. Since each user gets issued a unique cookie, we do not count the same user more than once even if they come to our website through different marketing channels.

The information collected using the conversion cookie is used to generate conversion statis-tics for Google Digital Marketing customers who have opted for conversion tracking. Custom-ers can see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that helps to identify users personally.

You can withdraw your consent by preventing the installation of cookies by setting your browser software accordingly (deactivating cookies). You are then not included in the con-version tracking statistics. Further information and Google's privacy policy can be found at: http://www.google.com/policies/technologies/ads/ and http://www.google.de/policies/privacy/

Google Tag Manager and Adobe Dynamic Tag Manager
On our website we use Google Tag Manager and Adobe Dynamic Tag Manager. Those are solutions that allow marketers to manage web page tags through a single desktop interface. The services themselves (which implement the tags) are cookie-less domains and do not col-lect any personal information. The services trigger other tags that may in turn collect data. Google Tag Manager and Adobe Dynamic Tag Manager do not access this data.

Kenshoo
We use Kenshoo, a service by Kenshoo, Ltd., 6 Habarzel St., Lobby B, 5th floor, Tel-Aviv, 6971010, Israel, to manage, optimize and analyze our digital marketing activities across multi-ple advertising channels and devices. The information collected by Kenshoo is typically used to identify trends and optimize our overall advertising activities. As such, the information col-lected by Kenshoo is un-identifiable, and they do not know, nor will we attempt to know the identity of users. Kenshoo uses tracking pixels and cookies to track users, who interact with our website and our ads. We use the aggregated data provided by Kenshoo, to measure the performance of our keyword advertising and of the conversions of multiple engagements across different channels, to detect market and industry trends, and to retarget users that left our website without taking action.

You can find out more about the handling of data as well as information on how to withdraw your consent by opting out of Kenshoo’s cookies in Kenshoo’s privay policy at https://kenshoo.com/privacy-policy/

The following cookies may be used on our website:
Provider: doubleclick.net / Google
Name: IDE
Usage: The cookie is used for retargeting, optimisation and dissemination of online advertis-ing. To opt out, please click here
Type: Third-party cookie
Validity: Two months

Provider: doubleclick.net / Google
Name: test_cookie
Usage: Test cookie
Type: Third-party cookie
Validity: Two months

Provider: emetriq
Name: ep    
Usage: unknown
Type: Third-party cookie
Validity:  1 year

Provider: emetriq
Name: pid / pid_short / pid_signature
Usage: unknown
Type: Third-party cookie
Validity:  1 year

Provider: Adobe Analytics
Name: 5.    AMCVS_097B467352782F130A490D45%40AdobeOrg / AMCV_097B467352782F130A490D45%40AdobeOrg
Usage: The cookies stores the number of days that have passed since the user last visited the page
Type: First-party cookie
Validity: Two years

Provider: Adobe Analytics
Name: s_cc
Usage: The cookie establishes if cookies are activated in the browser settings
Type: Performance cookie
Validity: Transient (until the end of the browser session)

Provider: Adobe Analytics
Name: dcdata    
Usage: This cookie saves data about further visited pages
Type: Performance Cookie
Validity:  Ten years

Provider: Adobe Analytics
Name: demdex
Usage: The cookie is set by the Audience Manager instead of an individual User ID
Type: Third-party cookie
Validity: 180 days

2. Active Use of the Website

In addition to the merely informational use of our website, you can also actively use our web-site to book an Audi or to contact us. In addition to the above-mentioned processing of your personal data for merely informational purposes, we will also process other personal data that we require from you to process your booking or to process and respond to your inquiry.

a. User Requests
In order to process and answer your inquiries to us, e.g. via the contact form or our e-mail address, we process your personal data provided by you in this context. In any case, this includes your name and e-mail address in order to send you an answer, as well as the other information that you send us in the context of your message.

To the extent a legal basis for our data processing activities is required under the GDPR, we process your personal data in order to respond to user inquiries on the following legal basis:
• to protect our legitimate interests pursuant to art. 6 para. 1 lit f GDPR; our legitimate in-terest is to answer customer inquiries appropriately.

b. Provision of our Services
We process your personal data, which you make available to us within the scope of conclud-ing or preparing a contract, making a request or otherwise and which is necessary for con-cluding the contract, for providing the services demanded, for answering to your request, to justify, execute and, if necessary, terminate our contract with you and the execution of your orders. We process personal data that we receive as part of a complaint in order to examine the incident and process it. However, we also use our customers' data to collect our claims.  

Where the provision of your personal data to us is voluntary, this is marked as such.

General Information
We process the following personal data of you, when you provide it to us online, in person or through another means of communication provided:
• First, middle and last name;
• Date of birth;
• Street address and house number, ZIP Code;
• e-mail address;
• mobile phone number;
• credit card information;
• driver’s license number and information.

Vehicle Operations and Usage Data
When you use Audi on demand, various categories of information will be stored within the Audi vehicle and may be transmitted during or after your use of the vehicle. This data includes the operational status of the Audi vehicle, including the engine, mirrors, brakes, temperature, flu-ids, vehicle speed, transmission, fuel level, battery, inspection information, key access, steer-ing wheel, headlights, whether doors or hood are opened, and other data points related to the access, status, location, and operation of the vehicle. Some of this information may be trans-mitted while the vehicle is being operated, while other categories of information are available to Audi once vehicles are returned.

Legal Basis
To the extent a legal basis for our data processing activities is required under the GDPR, we process your general information and your data regarding vehicle operations and usage on the following legal basis:
• to fulfil a contract or to carry out pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, if you have entered into a contract with us or use our services.

Data Processing based on our legitimate interests
Beyond the actual performance of the (preliminary) contract, we process your data, if neces-sary, where it is required to protect our legitimate interests or those of third parties, provided that your interests or fundamental rights and freedoms do not conflict with this. Justifiable in-terests may include our economic interests, our legal interests, our interest in complying with and ensuring compliance or IT security.

In this context we collect the following identifier and tracking information from your mobile de-vice, from the Audi on demand hardware installed on the Audi vehicle, or from your Internet browser on a desktop or laptop:
• Vehicle Identification Number (VIN);
• Authorization tokens;
• Mobile device identifiers;
• Geo-location, including both precise (GPS) and network-based geo-location;
• Log-in information;
• Bluetooth pairing information for your mobile device, including device identifiers;
• Unique identifiers contained in browser or Flash cookies;
• IP address;
• Information collected from web beacons, including data stored in cookies;
• The last page you visited before coming to the Web Portal and other browser related information

Additionally we may use all or part of the aforementioned information we collect to maintain our vehicle fleet, provide the full range of Audi on demand services, and find missing or stolen ve-hicles. We de-identify and aggregate certain records so that the information no longer identi-fies you or the Audi vehicle you used as far as this is possible and reasonable.

Legal Basis
To the extent a legal basis for our data processing activities is required under the GDPR, we process the aforementioned information on the following legal basis:
• for the performance of a contract or for pre-contractual measurements with regard to our performance of the offered services in accordance with Art. 6 para 1 lit. b GDPR where such data is mandatory to perform the requested services; or
• to protect our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in order to make our services technically available to you. Our legitimate interest is to provide you with an attractive, technically functioning and user-friendly service and to take measures to pro-tect our IT-infrastructure from cyber risks and to prevent our IT-infrastructure from pos-ing cyber risks for third parties.

Compliance with Legal Obligations

Like everyone who participates in economic activities, we are also subject to a large number of legal obligations. These are primarily statutory requirements (such as, but not limited to, commercial and tax laws), but also, where applicable, regulatory or other official requirements. The purposes of processing may include identity and age verification, fraud and money laun-dering prevention, the prevention, combating and investigation of terrorist financing and of-fences endangering assets, the fulfilment of fiscal control and reporting obligations and the archiving of data for the purposes of data protection and data security as well as verification by tax and other authorities. Furthermore, the disclosure of personal data within the frame-work of official/judicial measures may become necessary for the purposes of taking evidence, prosecution or the enforcement of civil law claims.

Therefore, to the extent a legal basis for our data processing activities is required under the GDPR, we process your personal data for legal compliance on the basis of the following legal bases:
• to fulfil a legal obligation to which we are subject pursuant to Art. 6 para. 1 lit. c GDPR in connection with the aforementioned rules and regulations.

c. Newsletter
With your consent we use your data for the transmission of our newsletter, for advertising surveys or invitations to events of interest to you, or we use your data for market research purposes. We collect mandatory information such as your e-mail address, first name, last name but also information that you voluntarily provide to us. We use the voluntary data to permanently improve our customer relationship and make it customer-friendly for you, to be able to address you individually in the future, to analyse your preferences and to inform you about the products of interest to you. You can unsubscribe at any time by clicking on the link provided in the newsletter to unsubscribe or by contacting our customer service at the con-tact address above.

Legal Basis
To the extent a legal basis for our data processing activities is required under the GDPR, we process your data for the dispatch of newsletters, surveys etc. and the personalization of the address on the following legal basis:
• If you have given us your consent, in accordance with Art. 6 para. 1 lit. a DSGVO;
• If you have provided us with your e-mail address in connection with the purchase of goods or services in the context of Audi on demand or if we send you personalised ad-vertising in order to safeguard our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO; our legitimate interest is based on our economic interests in the implementation of advertising measures and target group-oriented advertising.

Right to object
If we receive your e-mail address in connection with the conclusion of a contract for the pro-vision of our products or services and you have not objected to this, we may use your email-address to regularly send you commercial offers via email for similar products or services from our range of products. You can object to this use of your e-mail address at any time by sending a message to the contact option described above or by clicking a link provided for this purpose in every commercial e-mail.

III. Links

Some sections of our web pages may contain links to the web pages of third parties. These websites are subject to their own data protection principles. We are not responsible for their operation including the data handling. If you send information to or about such third party sites, you should review the privacy statements of those sites before you submit any information that may assigned to you.

IV. Categories of Recipients

Within our company group, the internal departments and all other companies affiliated with us under company law receive your data in such cases that the data is necessary in order to perform our contractual and statutory obligations or in the course of processing and imple-menting our legitimate interest.

Your data will only be passed on to the following external parties:
• Audi Singapore Pte Ltd and its affiliated companies;
• Affiliated companies within our group of companies, insofar as they act as data proces-sors for us and, for example, provide IT services or insofar as this is necessary for,
• Payment service providers and banks to collect outstanding payments from accounts or to pay refunds,
• Call centers and complaint processors to receive and process your inquiries and com-plaints,
• Agencies, printers and lettershops that support us in carrying out advertising measures, competitions, promotions, etc.,
• IT service providers who store data, support the administration and maintenance of the systems as well as file archivists and shredders,
• Collection companies and legal advisors in asserting our claims,
• public authorities and institutions insofar as we are legally obliged to do so.

Beyond the above mentioned, we will not pass on your data to third parties.

V. Transfer into Third Countries

By visiting our website and using our services, your data is processed outside of the EU/EEA. Furthermore, we may transfer data to other third countries. In these cases, the recipients are either situated in a country for which an adequacy decision by the Commission exists, the re-cipients have implemented Binding Corporate Rules or you can ask our Data Protection Of-ficer to provide you with a copy of the respective standard data protection clauses.

VI. Duration of Storage

1. Informational Use of the Website
When using our website for information purposes only, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our web-site, your personal data will be deleted immediately.
Cookies installed by us are usually also deleted after leaving our website. However, this does not apply to tracking cookies. These remain stored for the duration of up to two years. You also have the option to delete installed cookies yourself at any time.

2. Active Use of the Website and our Services

If you actively use our website, we initially store your personal data for the duration of re-sponding to your inquiry or for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.

In addition, we are subject to various storage and documentation obligations. We may store your personal data, as far as we are legally obliged to store it beyond the end of the business relationship or the pre-contractual legal relationship.

Furthermore, special legal regulations may require a longer storage period, e.g. the preserva-tion of evidence within the framework of the legal statute of limitations.

If the data are no longer required for the fulfilment of contractual or statutory obligations and rights, they are regularly deleted, unless their limited further processing is necessary to fulfil the purposes listed above under. In these cases, even after termination of our business rela-tionship or our pre-contractual legal relationship, we may store and, if necessary, use your data for a period compatible with the purposes.

VII. Your Rights as Data Subject

To the extent the GDPR applies, you are entitled to the following rights as data subject, which you can assert against us. Similar rights may exist under the PDPA.

Right to information: You are entitled to request confirmation from us at any time within the scope of art. 15 GDPR as to whether we are processing personal data relating to you; If this is the case, you are also entitled under art. 15 GDPR to receive information about such per-sonal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.

Right to correction: According to art. 16 GDPR, you are entitled to demand correction of the personal data stored about you if it is inaccurate or incorrect.

Right to deletion: You are entitled, under the conditions of art. 17 GDPR, to request from us the deletion of personal data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.

Right to limitation of processing: Under the conditions of art. 18 GDPR you are entitled to request from us the limitation of the processing of your personal data.

Right to data transferability: You are entitled, under the conditions of art. 20 GDPR, to re-quest from us the provision to you of the personal data relating to you that you have submitted to us in a structured, current and machine-readable format.

Right of revocation: You have the right to revoke your consent to the processing of per-sonal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.

Right to objection: You are entitled to object to the processing of your personal data under the conditions of art. 21 GDPR, meaning that we have to terminate the processing of your personal data. The right of objection exists only within the limits provided for in art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.

Right of appeal to a supervisory authority: You are entitled to file a complaint with a su-pervisory authority, in particular in the Member State of your place of residence, work or sus-pected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of personal data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.

However, we recommend that you always address a complaint to our data protec-tion officer first. If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our data protec-tion officer.

VIII. Scope of your Obligations to provide Data

Generally, you are not obliged to provide us with your personal data. However, if you do not provide this information, we will not be able to make our website available to you (for which we need at least your IP address), answer your questions (for which we need at least your email address) and enter into a contract with you. Personal data which we do not necessarily re-quire for the above-mentioned processing purposes are marked as voluntary information.

IX. Automated Decision Making/ Profiling

We do not use automated decision making or profiling (an automated analysis of your person-al circumstances).

Information about your right of ojection art. 21 GDPR (only applicable to the extent the GDPR applies)
1. You have the right to object at any time to the processing of your data on the basis if art. 6 para. 1 f GDPR (data processing on the basis of balance of interests) or art. 6 para. 1e GDPR (data processing in the public interest), if there are reasons for this arising from your particular situation. This also applies to profiling based on this provision within the meaning of art. 4 No. 4 GDPR.
 
If you object, we will no longer process your personal data, unless we can prove compelling and applicable reasons for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
 
2. We also process your personal data in individual cases for direct marketing purposes. If you do not wish to receive advertising, you have the right to object to it at any time; this also applies to profiling, insofar as it is associated with such direct advertising. We will take this contradiction into account in the future.
 
We will no longer process your data for direct marketing purposes if you object to the processing for these purposes.

 
The objection can be made without formality and should be addressed to
Premium Automobiles Pte Ltd.
281 Alexandra Road,
Singapore, 1599938
contact@sg.audiondemand.com

X. Amendments

We reserve the right to change this privacy policy at any time. Any changes will be an-nounced by publishing the amended privacy policy on our website. Unless otherwise speci-fied, such amendments shall take immediate effect. Please check this privacy policy regularly to ensure you have the latest version.


Last updated in August 2018