The Giltrap Group Limited group of companies, including European Motor Distributors Limited, trading as Volkswagen New Zealand (collectively referred to as "Volkswagen NZ", “our”, “us” or "we") is committed to protecting the privacy of the personal information of our current, former and potential customers (referred to as “customers”, “you” and “your”).
If we are unable to collect sufficient personal information, we may not be able to provide you with the full benefit of our products, services and offers or our online and digital platforms.
Our authorised Volkswagen dealers (“Authorised Dealers”) are independent business entities and may have privacy policies which are different to ours. Authorised Dealers are responsible for their own privacy policies and privacy practices. Please contact your Authorised Dealer directly for enquiries or further information.
2. What types of personal information do we collect?
We only collect and process personal information that we consider necessary for the effective functioning or activities of our business. Generally, the types of personal information that we collect from or about you depends on the circumstances in which the information is collected. We have described below examples of the types of personal information that may be collected, however this is not an exhaustive list:
- The main type of personal information that we collect is your name and contact details, including physical and postal address, email addresses, phone numbers, and mobile numbers.
- Our Authorised Dealers will collect your driver’s license details when you participate in a test drive or when you purchase a vehicle and we may be recipients of this information.
- Other personally identifiable information such as demographic information about your age, gender and occupation, as well as information about your hobbies, favourite sports and other interests and preferences may be collected if you choose to provide us with that information, for example when entering a competition or promotion or taking part in a customer experience survey following the purchase or service of your vehicle.
- We may collect your airline membership number for the purpose of facilitating the award of airpoints in relation to your purchase (if applicable);
- We may collect financial and credit information if you are seeking to obtain finance for the purchase of a vehicle, and if you finance your vehicle with Volkswagen Finance, we may collect information about the finance, such as the amount financed and the type of finance product.
- We will collect information about your vehicle, including its number plate, vehicle identification number (VIN), and service plan schedule.
- We may collect information relating to your dealings with Volkswagen and/or our Authorised Dealers (such as details of vehicle/s purchased, service and repair history, and responses to other questions that we may ask).
- If you request or receive roadside assistance services, we may collect information about where (e.g. location) and when (e.g. date, time) you requested roadside assistance services and the assistance service that is required.
- We may collect other types of information you provide us when making enquiries or providing feedback on our or our Authorised Dealers’ products and services, for example enquiry details, your opinion on products and services, and records of your communications with us.
- We may collect information which you allow to be shared with us that is part of your public profile on a third-party social network, or information you create and share with us by posting it to one of our social networks.
- We may collect information relating to the way you use or navigate any of our websites, customer portals and mobile applications so that we can improve your experience and our communications with you online.
- If you use any of our Volkswagen mobile applications, we may collect information (some of which may be personal information about you), including:
- the number of trips and distances that you have driven;
- the location of your vehicle, including historical locations and past driving history;
- vehicle diagnostic information, such as tyre pressure, amount of fuel in the tank and engine information;
- vehicle driving information, such as speed, braking and acceleration information; and vehicle fuel efficiency;
- mobile phone information such as number, model, operating system and personal location data where you have activated location services on your mobile device; and
- any mobile contact numbers entered in the applications for additional services relating to emergency contacts.
- We may also collect other personal information as otherwise permitted or required by law, as well as any other information that you choose to provide us.
3. How is personal information collected?
We may collect personal information from or about you in a variety of ways. Where possible we will collect personal information directly from you. The most common ways we collect personal information are:
- information you provide us directly either in person, over the phone, by email, or through our digital and online channels, for example:
- if you make an enquiry about Volkswagen vehicles, parts, accessories or services, or if you request a test drive, brochure, specification sheet, information or other materials about Volkswagen vehicles, parts, accessories or services;
- if you interact with us online, including via our websites or through social media channels;
- If you use our customer portal and/or any of our Volkswagen mobile applications;
- if you enter a promotion or competition carried out by Volkswagen directly or carried out by a third party with official affiliation with or support from Volkswagen;
- if you participate in a marketing, product development, profiling, survey or market research campaign, including on social media channels; or
- if you request roadside assistance services;
- we will collect personal information from our Authorised Dealers (e.g. information you provide when you purchase a new or used Volkswagen vehicle, part or accessory from an Authorised Dealer, arrange finance for the purchase of your Volkswagen vehicle, take a test drive at an Authorised Dealer, or have (or book in to have) your Volkswagen vehicle serviced or repaired at an Authorised Dealer);
- we may collect personal information from Volkswagen AG and its related entities, service providers, contractors, and agents (e.g. if you participate in a customer survey managed by Volkswagen AG.
- we may also collect personal information about vehicle owners from the Motor Vehicle Register, in accordance with our authorisation to access this register for specified purposes under section 241 of the Land Transport Act 1998
- we will collect your personal information from the third-party provider of Volkswagen Finance if you arrange finance for a Volkswagen vehicle through Volkswagen Finance; and
- in certain circumstances we may also collect your personal information from other third parties, including our related entities, service providers, contractors, and agents.
4. For what purposes do we collect, hold, use and disclose personal information?
We only collect, hold, use and disclose personal information for the purposes for which it was originally collected (and for related purposes which you would reasonably expect), unless required or authorised by or under law or if the individual concerned has consented to another use. Some of the specific purposes for which we collect, hold, use and disclose personal information include:
- to enable us to correspond with you and do business together and for reasons related to our business operations, such as to ensure we and our Authorised Dealers continue to deliver quality products and services to our customers and potential customers;
- to assist in administering your vehicle purchase, lease, warranty, any extended service plan, roadside assistance, or ongoing vehicle service, and arranging for our Authorised Dealers to obtain required vehicles and parts on a timely basis to meet your needs;
- to facilitate your application for finance for the purchase of your vehicle;
- to respond to your enquiries, comments, concerns or requests for information about our vehicles, parts, accessories, services or offers;
- to process sales orders and administer accounts, warranty records and vehicle service records;
- to provide you and our Authorised Dealers with necessary support;
- to attend to or assist in the servicing or repair of your vehicle, including the provision of roadside assistance services and online vehicle service and repair booking facilities with or for Authorised Dealers;
- for product development, market research, and customer surveys (for example, to obtain your feedback and find out your level of satisfaction with our products and services and with our Authorised Dealers);
- for marketing and promotional activities, including to contact you directly or through our (or our affiliates’) service providers and research agencies for these purposes;
- to carry out our legal compliance obligations, such as to conduct a product safety recall where necessary or inform you of a customer notification or field service action affecting your vehicle;
- if you use any of our Volkswagen mobile applications to provide you with notifications and information about your vehicle;
- to send you service and Warrant of Fitness reminders;
- to contact you with details of new Volkswagen vehicles, products or services, or automotive products offered by other parties, or special offers or promotions that we think may be of interest to you;
- to assist our Authorised Dealers in performing any of the purposes outlined above (if applicable);
- we may use information collected from our websites to enable the features of the websites, to improve the websites by determining which of our products, features and services are most popular, and to personalise the experience of the users of our websites;
- we may also process your personal information for other purposes which are disclosed to you, and to which you consent, whether expressly or by implication by providing us with your personal information with knowledge of how we intend to use it; and
- we may also process your personal information without your consent for purposes that are required or authorised by or under any applicable law, including but not limited to meeting our legal obligations, assisting in the investigation of a breach of an agreement or a law, assisting in law enforcement purposes, and protecting our and our customers’ business interests.
5. Who has access to your personal information?
- our employees, officers, contractors, service providers, agents, and partners (for example, mailing houses, marketing agencies, airline programme partners, market research providers, printers, roadside assistance service providers, insurance providers, financiers, website and data hosting providers, data analytics providers, and other IT suppliers);
- our related or affiliated companies and their respective employees, officers, contractors, service providers and agents (and our related or affiliated companies may disclose the personal information directly to their contractors, service providers and agents);
- our Authorised Dealers (and vice versa);
- Volkswagen AG and its affiliated or related companies and its and their respective employees, officers, contractors, service providers, dealers, agents, partners, and licensees (and Volkswagen AG and its affiliated or related companies may disclose the personal information directly to their respective contractors, service providers, dealers, agents, partners, and licensees);
- our accountants, insurers, lawyers, auditors and other professional advisors;
- if your vehicle is provided by your employer as part of a corporate or government fleet policy, we may also disclose certain personal information to your employer;
- any other third parties to whom you direct or permit us to disclose your personal information (e.g. third parties with whom we have directly or indirectly arranged services for your benefit);
- third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- as otherwise permitted or required by or under any applicable law.
In the unlikely event that we sell a part of or the whole of our business, or we are no longer the authorised importer of